GIPS - Those nagging questions!

(have searched thoroughly, if anyone can answer it would be much appreciated!) 1. Standard 5.A.3: Firms may link non-GIPS-compliant returns to their compliant history so long as the firms meet the disclosure requirements for noncompliant performance and only compliant returns are presented for periods after Jan 1/2000 Does this basically mean, for thestandard where you have to present the minimum of 5 years of returns or since inception, that you can use non-compliant returns if they are before 2000 to gain compliance (provided you do appropriate disclosures for non-compliant returns)? 2. The famous: must present five years or since inception of returns. After presenting at least 5 years of compliant history, must add annual performance each year going forward up to 10 years, at a minimum. The way I read this, it means you CANNOT backfill with >5 years of GIPS compliant data. You can only present 5 years of past compliant (or non-compliant pre-2000 with disclosures) data and MUST fill in the remaining five years with “fresh” returns generated each year. Can anyone give a solid confirmation on either of these? I think nailing these down for good would benefit everyone. Thanks!

Don’t know about the first one. But yes to the second one.

  1. There is a disclosure requirement 4.A.15 which requires you to disclose periods of non-compliant returns before 1/1/2000. I think pre-2000, GIPS were not standardized so firms CFAI allowed firms to present non-compliant data before 1/1/2000. The ONLY non compliance results which may be presented (with disclosure) are pre 1/1/2000. 2) The way I understand it if you are in compliance since inception (lets say 2003) you can present GIPS compliant results since 2003. It is 5 years min or since inception. (page 273).