3 Year Ex Post Standard Deviation

Required after 1/1/2011.

Arcadia Topic Test doesn’t include any ex-post standard deviation and its performance goes to Q1 2013 and it is in compliance! Is this because you won’t have 3 years of ex-post annualized standard deviation until 12/21/2013?

Technically you could use 2009, 2010, and 2011 data to present at year end 2011 to be compliant no?