Additional comments are provided in Annex 2: Additional comments to the GIPS 2020 Exposure draft.

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1 AXA Investment Managers Affolternstrasse 42 CH 8050 Zürich CFA Institute Global Investment Performance Standards Re: GIPS 2020 Exposure Draft 915 East High Street Charlottesville, VA USA Samuel Mürner +41 (0) Zürich, Comment of AXA IM to the Exposure draft of the 2020 GIPS standards Dear Ladies and Gentlemen We are pleased to send you herewith our comments to the GIPS 2020 exposure draft. Our detailed responses to your questions are addressed in Annex 1: Answers to Questions for Public Comment in the GIPS 2020 Exposure Draft. Additional comments are provided in Annex 2: Additional comments to the GIPS 2020 Exposure draft. Before detailing our view on the proposed standards under GIPS 2020 we would like to share some information about us which might help you when reading our responses. AXA Investment Managers is an active, long-term, global, multi-asset manager. AXA IM is part of the AXA Group, a world leader in financial protection and wealth management. Our investment capabilities are organized across multiple strategies consisting of Fixed Income, Framlington Equities, Rosenberg Equities, Real Assets, Multi Asset Client Solutions, Structured Finance and AXA IM Chorus. AXA IM is managing assets worth 760 billion Euros. AXA Investment Managers is a firm comprising of two sub-firms for GIPS purposes: - AXA IM with management centers including AXA Investment Managers Paris, UK, Luxembourg, Germany, Italy, Switzerland, Hong Kong, Tokyo, Australia, AXA IM Inc. and all Fund of Hedge Funds. - AXA Rosenberg Investment Management with offices in the U.S., U.K., Japan, Singapore and Hong Kong. Globally we welcome the new structure of the GIPS 2020 standards, in particular the separation into three themselves complete sections for traditional composites, funds and for asset owners. Where we do have the most concern about is the differentiation made between limited and broad distribution funds. Traditional funds are often offered to both, retail investors through various distribution means and on a one to one basis to institutional clients. Typically by using dedicated share classes or rebate models. AXA Investment Managers Schweiz AG - Tel : Fax : Hauptsitz : Affolternstrasse 42 - Postfach CH-8050 Zürich - Website :

2 Thus we see the requirements for limited distribution funds as a burden for such models without additional protection or additional transparency gain for the concerned investors. This is especially true in highly regulated fund markets and even in low regulated markets the GIPS 2020 standards will not lead to a better protection of retail clients. Therefore we suggest to refrain from this separation and not to require any specific fund report to be produced. Instead a requirement for a fund report for any fund when local regulation does not require so could address the need for enhanced transparency and protection. Furthermore we suggest adding a clear statement that firms may choose to continue to include their pooled funds in GIPS composites and as such are not obliged to follow the pooled fund requirements, even when managing such structures. We hope our remarks and answers will contribute to modern, easy to use and comprehensive framework for the GIPS 2020 standards. Yours sincerely AXA Investment Managers Schweiz AG Samuel Mürner Head of Operations Annex 1: Answers to Questions for Public Comment Annex 2: Additional comments to the GIPS 2020 Exposure draft Seite 2 / 17

3 Request for Comment #1 We use the terms limited distribution pooled fund and broad distribution pooled fund. A limited distribution pooled fund is typically sold in one-on-one presentations and offers participation in that specific fund (e.g., hedge funds, commingled funds). In some markets, these funds are not highly regulated. Broad distribution pooled funds are typically sold to the general public, and the firm may not know the client. These funds are typically highly regulated. Are the terms limited distribution pooled fund and broad distribution pooled fund easily understood? Are there terms that would better differentiate these two categories of funds? One suggestion is to use the terms private funds and public funds. Answer AXA IM: We believe the terms limited distribution pooled fund and broad distribution pooled fund is more comprehensive than alternative terms like private funds or public funds. Whereas whichever terms used, it does not address the common case that funds are in fact distributed to both, institutional clients and retail clients through their respective share classes. So both models will actually apply to a fund. Alternatively the differentiation could be made based on the targeted investors, similar for example like in the MIFID regulations (e.g. sold to qualified investors, retail investors, both). Also we ask ourselves if a fund, even constructed to serve public distribution, which contains a single (institutional, intermediary) investor, then must be defined as limited distribution fund by definition. Here some clarification in the standard would be welcomed. Generally we are not happy with this differentiation since as outlined above typically funds are serving both, the distribution and the institutional channels, thus there is no relief from the new guidelines when instead of a composite report an additional fund report needs to be produced (next to the fund reports produced anyway such as PRIIPs, UCITS-KIID, Fund Fact Sheet). We recommend pooled funds generally to be excluded from any reporting requirement, unless they will keep being allocated to a composite. For qualified investors usually the need for a standardized fund report is low if not otherwise already available (Fund Fact Sheet, KIID), and retail investors which actually could profit from such transparency rules are left beside since no fund report is required. This seems contradictory to us and this separation does not serve to create greater transparency in the fund market (in particular for retail investors which need the most protection actually). We understand that the CFA institute seeks to motivate fund managers to apply the GIPS standards as well. And for unregulated markets indeed a pooled fund report may help. But again, by only requesting this for limited distribution funds in our view the goal of increased transparency is missed whilst fund managers in highly regulated markets may refrain from adopting when having both types of distribution models applied to the same fund. Request for Comment #2 Currently, the GIPS standards are silent on how quickly firms must update GIPS compliant presentations. (The term compliant presentation has been replaced with GIPS Composite Reports and GIPS Pooled Fund Reports. We also use the term GIPS Report to include both GIPS Composite Reports and GIPS Pooled Fund Reports.) Some firms present returns that are several years old, often providing as the rationale the fact that they are waiting for the verification to be completed before updating the reports. We believe that firms should be required to update GIPS reports on a timely basis, even if the verification is not complete. Do you agree that firms should be required to update GIPS reports within a specified time period? Do you agree that six months is the appropriate amount of time? Answer AXA IM: We agree that GIPS reports shall be updated within a specific time period whilst we suggest requiring at least an annual update rather than every six months. Request for Comment #3 Firms are required to include terminated pooled funds on the respective list for at least five years after the pooled fund termination date. This approach is consistent with the requirement for the list of composites. Is it appropriate for firms to include terminated pooled funds on these lists when the pooled funds are not available for prospective investors? Answer AXA IM: No we don t think this is of any use for prospective investors. For Composites it might make sense to still list discontinued composites for a period of time as the IM could probably re-start the strategy if asked to. For funds there is little chance that it will come back in the same form. We therefore suggest allowing firms to removed closed funds from the list immediately. Generally we believe the list of composites, funds or whatsoever is of little use for prospective investors and more an administrative burden for the firm. Usually prospects are being offered or are asking for a specific strategy or fund and gain no value from the possibility to request an exhaustive list. Only consultants might need Seite 3 / 17

4 that in order to update their databases. For this it would be sufficient to recommend having such a list rather than to require it (although we acknowledge that such a list eases the work of verifiers, though probably not in case of discontinued funds). Request for Comment #4 Currently, firms are required to provide a complete list of composite descriptions to any prospective client that makes such a request. Under the new GIPS 2020 structure, firms can manage strategies for three types of products: composites, limited distribution pooled funds, and broad distribution pooled funds. This approach also creates three types of prospects: prospective clients for composites, prospective investors for limited distribution pooled funds, and prospective investors for broad distribution pooled funds. Considering limited distribution pooled funds, we expect that firms would either wish to or would be required by regulation to tailor the list of these funds to the individual prospect. For example, a firm that offers these funds to prospects throughout the world would include only the funds appropriate to an investor in Switzerland if a Swiss prospect asked for this list. Do you agree that firms should be required to provide a list of only those funds that are appropriate to the specific prospect? Unlike the lists for composites and limited distribution pooled funds, which must include both the name and the description of either all composites or limited distribution pooled funds, firms that manage broad distribution pooled funds would instead be required to have a list of such funds, and provide that list upon request. As a second step, firms would be required to provide the description of any broad distribution pooled fund upon request. We took this approach to acknowledge that many firms manage very large numbers of such funds, and maintaining a list of descriptions could be very challenging. We also acknowledge that most firms have very limited contact with prospects for these funds, if any. Do you agree with this two-step approach for broad distribution pooled funds? Answer AXA IM: We dislike the requirement to maintain any lists for pooled funds. As correctly pointed out these lists would need to be tailored per market in which the funds are registered. In particular for retail funds there exist various platform through which investors can gain an oversight of the funds offered by a firm, there is no need to maintain an additional set of lists. And again, also for private funds we see little use of such a list. We feel this is rather an attempt to keep the concept consistent across the standard which we believe is not necessary for funds. Beside that there is already enough information available for interested prospective clients (e.g. KIID, fund platforms, website of the fund management company, etc.). Request for Comment #5 In the GIPS 2010 edition, the notion of portability hinges on the requirement that performance from a past firm or affiliation must be linked to or used to represent the historical performance of a new or acquiring firm if, on a composite-specific basis, certain criteria are met. We have received feedback over the years that firms that do not want to meet the criteria will not do so, and portability will not be achieved. We decided to change the perspective and allow firms to choose to port returns if certain criteria are met. Do you agree that firms should be allowed to choose, for each composite or pooled fund, when returns from a prior firm or affiliation are used to present the historical performance of the new or acquiring firm, if certain tests are met? The one-year grace period allows a firm that acquires a non-compliant firm to not lose its compliant status because it does not immediately meet the requirements of the GIPS standards for the acquired assets. Do you agree that the one-year grace period should apply only to performance at the new or acquiring firm, and that firms should be able to port history from the prior firm or affiliation after the one-year grace period? In addition to the three tests that a firm must meet if it wishes to link performance from a prior firm or affiliation, there is a fourth test that must be met. There must not be a break in the track record between the prior firm or affiliation and the new or acquiring firm. Should this test be specified within this provision? Answer AXA IM: If the past firm was not claiming GIPS compliance (and never built composites), would portability be possible on individual portfolio level? I.e. to integrate the past firms portfolios into the new firms composites on a case by case basis? The one year grace period is generally welcomed and deemed suitable. The no-break test should be included, yes. Request for Comment #6 Firms may choose to present money-weighted returns instead of time-weighted returns for a specific composite or pooled fund if the firm controls the cash flows and meets at least one of the additional criteria for the composite or pooled fund. Are the additional criteria the correct criteria for determining if money-weighted returns may be presented? Are the appropriate names used for these additional criteria? Seite 4 / 17

5 Should firms instead be required to present money-weighted returns versus time-weighted returns for a specific composite or pooled fund when the firm controls the cash flows and it meets at least one of the additional criteria? Answer AXA IM: Whilst the first three criteria seem clear and suitable we believe the fourth criteria is not precise enough and leaves room for misinterpretation or even misuse. Nearly any investment can be deemed illiquid; there is no common definition of this. Also the term significant should be defined precisely in order to prevent from misusing it to avoid presenting TWR s (e.g. 50%). Generally we are against including illiquid investments as a reason for not presenting TWR s. Also for illiquid instruments there exist well proven market practices to still value the investment in order to have at least a monthly valuation in line with fair value practices. Also we would like to point out that even for traditional open ended funds the management company has the rights to suspend or alter S/R orders or to decline orders completely, considering this as a measure to control cash flows literally open ended funds could claim to present MWR s also. Request for Comment #7 Currently, total firm assets must include both discretionary and non-discretionary assets managed by the firm. In the GIPS 2020 Exposure Draft, this requirement still holds. In the GIPS 2020 Exposure Draft, however, we allow firms to present advisory-only assets that are not managed by the firm but require that advisory-only assets be presented separately from total firm assets. This approach is to recognize that many firms business models are changing. Also, firms have approached the treatment of committed capital differently when calculating total firm assets. Some firms consider committed capital to be part of total firm assets because the firm is charging an investment management fee on the committed capital. Other firms exclude committed capital because it is not under management before capital is called. We propose that firms must not include committed capital in total firm assets. Do you agree that firms should be required to not include advisory-only assets in total firm assets? Do you agree that firms should be required to not include committed capital in total firm assets? Answer AXA IM: We agree that firms may report advisory-only assets separately to the total firm assets. We agree that firms should not include committed capital in the total firm assets. Request for Comment #8 Currently, all returns must be calculated after the deduction of actual trading expenses incurred during the period, and estimated trading expenses are not allowed. When the GIPS standards were originally created, trading expenses were generally higher than they are now and were more standardized. Today, trading expenses can be charged in a variety of ways and may not be under a firm control. Indeed, in some instances, firms may not have the ability to determine how or where trading expenses are charged. We have decided to introduce allowing estimated transaction costs (the term that replaces trading costs) for composites if returns calculated using estimated transaction costs are equal to or lower than those that would have been calculated using actual transaction costs. Do you agree that estimated transaction costs should be allowed? Do you believe that firms will have the ability to determine if estimated transaction costs are more conservative than actual transaction costs? Research costs and their relationship to transaction costs have become a focus in some markets. We do not specify how research costs must be treated, and we also do not require any related disclosures. Should firms be required or recommended to treat research costs in a specific way? Should firms be required or recommended to disclose how research costs are reflected in returns? Should firms be required or recommended to disclose if research costs are separately charged to clients? Answer AXA IM: We believe that the test whether estimated transaction costs are equal or higher than actual trading costs will be hard to be made. As such we have no objection against allowing estimated trading cost but we recommend to precise that an estimate is only possible when the actual costs are unknown or not directly observable to the IM. And instead of the test firms should rather disclose the approach they have chosen to estimate these costs. If research costs are debited to the portfolio/fund concerned, then they should be treated the same way as management fees Request for Comment #9 The Guidance Statement on Alternative Investment Strategies and Structures provides guidance for firms that manage alternative strategies if the firm places reliance on valuations that are received with a significant time lag (e.g., for portfolios or funds invested in third-party hedge funds). There is some concern that firms may adopt the use of preliminary, estimated values for liquid strategies where more appropriate valuations are available. Seite 5 / 17

6 Should this guidance be limited to certain types of assets, such as investments in third-party private market investment funds? Should this guidance instead continue to be included in guidance rather than included as a provision? Answer AXA IM: In our view the term fair value does sufficiently define the use of estimated market values in absence of real quotes. In case of using estimates due to the absence or lag of valuations we suggest not to require any adjustment and rather recommend that in such case the firm has to choose whether or not to use estimates instead of real valuations but then needs to stick to whatever method chosen. Request for Comment #10 When calculating since-inception internal rates of returns (now referred to as money-weighted returns), currently private equity portfolios are required to use daily external cash flows for periods beginning on or after 1 January Real estate closed-end funds are required to use quarterly or more frequent external cash flows. It is proposed that all portfolios and pooled funds, including private equity, would be required to use daily cash flows when calculating money-weighted returns for periods beginning on or after 1 January 2020, and quarterly external cash flows for periods prior to 1 January Do you agree that firms should be required to use daily external cash flows as of 1 January 2020 when calculating money-weighted returns? Is the change to lessen the required frequency for private equity for periods prior to 1 January 2020 appropriate? Answer AXA IM: We agree that daily external cash flows shall be required for MWR s across the band. We do not see that with an effective date of the GIPS 2020 standards as of Jan 1st 2020 private equity firms will be allowed to move away from daily cash flows prior to the effective date, till then still the current provisions requiring daily cash flows apply? Furthermore we do not see a reason why not also for MWR s presented the same periods should be required than for TWR s presented (e.g. annual returns). We feel that due to the broader use of MWR s possible prospective clients might be confronted with both, composite reports based on MWR and composite reports based on TWR for the same strategy requested. Then such differences in periods to be reported make it difficult to compare managers between each other. We are also not in favor of a quarterly rather than a monthly return calculation being required for private market portfolios using TWR. There is no reason for this relaxation, and if a private market firm is not capable of doing so still it could present annual and period to date MWR s. Request for Comment #11 Currently, real estate investments are required to receive an external valuation at least once every 12 months, with an exception for when clients opt out of the external valuation. In that case, firms must obtain an external valuation at least once every 36 months. We expanded the notion of external valuation beyond the current requirement for real estate to private market investments but broadened the type of valuations that are allowed. Private market investments include real estate, infrastructure, timberland, private equity, and similar investments that are illiquid and not traded on an exchange. These assets must have an external valuation, valuation review, or be subject to a financial statement audit at least once every 12 months. Do you agree that private market investments should be required to have an external valuation, valuation review, or be subject to a financial statement audit? Is once every 12 months the appropriate valuation frequency given the expanded types of valuation that are allowed? Are there any other types of valuation that should also be allowed? Answer AXA IM: We think with the term Private Market Investment this requirement is not catching all possible scenarios and is not clear whether this is meant to be applied on the level of the portfolio or fund or on the level of its investments. For example there could be well alternative or illiquid assets including real estate, private equity etc. in open ended structures. What does this provision mean to such vehicles? Should this external valuation not rather been dealt with under the Fair Value provisions, e.g. in absence of market quotes alternative models such as estimated market values or external valuations can be used. The latter must be renewed at least on an annual basis. And we think it is not the purpose of the GIPS standards to require external valuation reviews and audits. Under the fair value provision there could be a recommendation to have alternative pricing models reviewed or audited. Request for Comment #12 Currently, firms are required to present returns both with and without side pockets, when a composite includes only one pooled fund that has discretionary side pockets. Composites with multiple portfolios are not required to present returns both with and without side pockets. To eliminate differences between composites and pooled funds, and to acknowledge that firms should be accountable for all returns, including those of side pockets, firms Seite 6 / 17

7 will be required to present returns that include side pockets. Firms will not be required to present returns that do not include side pockets. Do you agree with this approach? Answer AXA IM: Since side pockets are non-accessible for new investors we rather would prefer to exclude side pockets and treat them like non-discretionary assets, in case of distressed assets this assumption certainly holds true. So side pockets would still count for the total firm AUM, but not dilute returns presented to prospective clients. Request for Comment #13 Firms are recommended to use gross-of-fees returns when calculating risk measures. Do you believe that firms should instead be recommended to use net-of-fees returns to calculate risk measures when only net-of-fees returns are presented in a GIPS Composite Report or GIPS Pooled Fund Report? Would your answer differ when there are performance-based fees or carried interest? Answer AXA IM: This is a difficult question to be answered, whilst from investors perspective the risk measures calculated based on net returns reflects correctly the risks associated with his investment this is not the case for prospective clients looking for a segregated account, but it is true for prospective pooled fund investors provided there are no rebate structures being applied to their investment. At the same time it is common practice to calculate risk measures based on gross returns in particular for pooled funds also the net approach is wide spread. Therefore we believe both should be allowed with a clear disclosure (whilst requiring gross risk measures when gross returns are being presented). Request for Comment #14 Currently, firms are allowed to create sponsor-specific composites that include only that specific sponsor s wrap fee portfolios, when presenting performance to that sponsor. We removed the concept of a sponsor-specific wrap fee composite. Firms may still present sponsor-specific performance, but we view this as client reporting versus composite reporting to a prospective client. We also changed the term from wrap fee/sma to wrap fee. Do you agree with these changes? Answer AXA IM: Agree. Request for Comment #15 To be responsive to specific constituencies, including private wealth managers and managers of private market investments, we propose that firms may once again allocate cash to carve-outs. If firms choose to allocate cash to a carve-out, they must do this for all carve-outs managed in that strategy. Once a firm obtains a standalone portfolio managed in the same strategy as the carve-out, the firm must create a composite that includes only standalone portfolios and must present the performance of this composite alongside the performance of the composite that includes carve-outs with allocated cash. Do you agree that firms should be allowed to include in composites carve-outs with allocated cash? Should firms be required to use a specific method to allocate cash to carve-outs? Do you agree that firms should be required to create and maintain a composite that includes only standalone portfolios? Answer AXA IM: We strongly disagree to once more allow allocated cash in order to include carve-outs in composites. With the current standards even when some carve-outs of the same strategy have its own cash whilst others have not it is possible to allocate the true carve-outs to composites whilst keeping non-true carve outs besides and only allocate their portfolio. With allowing allocated cash and at the same time requiring this to be applied to all carve-outs of the same strategy it could result in firms refraining from building true carve-outs at all. Furthermore we object to the requirement to maintain two sets of composites for the same strategy, once with and once without carve-outs, this is not serving the purpose of being able to present the capacity of an investment manager to a prospective client for such a strategy. Again, we do not see any need for relaxing the rules for carve-out creation in terms of its cash, in contrary this meant to be relaxation is rather introducing additional complexity to the subject. However we understand that this relaxation is an attempt to make it easier for private equity or alternative asset managers to adopt GIPS. A compromise could maybe be to ban cash allocation for carve outs in traditional composites, but allowing them for limited distribution funds. This compromise keeps the status quo for current GIPS compliant firms and makes it easier for non-gips compliant private equity managers to allocate cash for their carve outs. Request for Comment #16 In GIPS 2010, firms are required to present income and capital component returns for real estate composites. When calculating these component returns, firms are required to calculate each component return separately. As part of the move to eliminate asset class provisions, we have deleted these real estate specific requirements and Seite 7 / 17

8 have expanded the concept of component returns to all composites and pooled funds. Firms would be allowed to derive one of the component returns as the difference between the total return and one of the calculated component returns. We acknowledge that component returns are widely used in some markets, but not in others. We therefore are recommending component returns to be included in GIPS Composite and Pooled Fund Reports that include time-weighted returns, and we expect that firms will present component returns where it is customary for a specific market to do so. Do you agree with eliminating the requirement for real estate portfolios to present component returns? Do you agree with eliminating the requirement for real estate portfolios to separately calculate component returns? Do you agree that component returns should be recommended for all composites and pooled funds when timeweighted returns are presented? Answer AXA IM: Why should the recommendation to present component returns only be limited to TWR s presented? Regardless if in the context of GIPS a TWR or a MWR is being presented for a property portfolio or fund, the information about income from the properties is a key ratio and mandatory to be presented separately at least for real estate funds in regulated markets. However we agree with the removal of the requirement for real estate portfolios since this is rather a matter of financial reporting regulation for such vehicles in their respective jurisdiction. But at the same time we believe it is not the purpose of an investment performance standard to regulate this and as such suggest to remove the recommendation for TWR s being presented. In particular since this recommendation indeed would not intuitively concern most of the asset classes. Request for Comment #17 We frequently hear that too many disclosures are required in GIPS reports. We have introduced sunset provisions where possible that is, although all disclosures must be included for at least one year, some disclosures may subsequently be deleted once the firm determines that they are no longer relevant to interpreting the performance track record. Do you agree that firms should be allowed to delete some disclosures once the firm determines that they are no longer relevant to interpreting the performance track record? Did we correctly identify the disclosures that should be allowed to be deleted once the firm determines that they are no longer relevant to interpreting the performance track record? Answer AXA IM: Yes, we welcome this new sunset provision. Former changes to the minimum asset level, as well as past firm or composite redefinitions should also fall under this provision. Request for Comment #18 A Guidance Statement on Overlay Strategies has been exposed for public comment but has not been finalized. A key concept within this Guidance Statement is discussion of the various methods that can be used to calculate returns for overlay strategy portfolios. Because of the unique nature of overlay strategy portfolio return calculations, we propose requiring firms to disclose details about these calculations. Do you agree that firms should be required to disclose details about these calculations for overlay strategy composites? Are there other disclosures that would be meaningful that are specific to overlay strategy returns calculations? Answer AXA IM: We agree that such a disclosure is helpful. We do not see other disclosures needed. Request for Comment #19 We have expanded the ability to present money-weighted returns beyond private equity composites and closedend real estate funds, if certain criteria are met. In GIPS 2010, compliant presentations for private equity composites and closed-end real estate funds are required to include since-inception internal rates of return (now renamed money-weighted returns) through each annual period end. For example, a private equity composite that has been in existence for four years would present four since-inception money-weighted returns. We propose to instead require firms to present money-weighted returns for only one period: from the composite s inception through the most recent annual period end. Do you agree that firms should be required to present returns for only one period from inception through the most recent annual period end? Answer AXA IM: Due to the wider use of MWR potentially allowed which will well include strategies for which certain firms still present TWR s whilst others decide to present MWR s we believe it is in the interest of any prospective investor in such a strategy to require annual returns to be presented same as for TWR composite reports. Otherwise comparability will suffer. Thus we suggest requiring the same periods to be presented for both TWR and MWR based composite reports. Seite 8 / 17

9 Request for Comment #20 Subscription lines of credit are being used by more firms and for longer periods. These lines of credit can have a significant effect on returns. As has been widely discussed in the industry, there has also been a lack of consistency in return calculations when lines of credit are used. For comparability and transparency, we propose requiring firms to present returns both with and without the subscription line of credit activity, whenever any line of credit has been used. A return with the line of credit reflects line of credit activity as an external cash flow. Do you agree that firms should be required to present returns both with and without the subscription line of credit activity? Should we be describing returns with and without the subscription line of credit differently? For example, some firms refer to these returns as levered and unlevered returns. Do you agree that firms should be required to treat all lines of credit the same and not differentiate between short-term and long-term lines of credit? We propose requiring returns with and without the subscription line of credit activity only when money-weighted returns are presented. There is no comparable requirement when time-weighted returns are presented. Do you agree that this is the correct approach? Answer AXA IM: Firstly we understand that also commitment based funds may present TWR s. Thus there could be such a fund with a subscription line of credit facility that would not need to apply any measures to the returns presented simply because it falls under the TWR composite return report guidelines which do not contain such a requirement. Then we do not see a material difference (in the effect to a portfolio or fund return) between a subscription credit line, any other form of credit line or the use of leverage, all allows the IM to maintain a fully exposed portfolio without needing to have it fully funded. Therefore we believe it is fair to present only returns with a credit line used (if applicable, unused credit lines should not be considered at all) and in the end to present returns calculated over the invested portfolio/fund only. Also we do not really understand what the return without credit line actually should represent or how it has to be calculated. If this still will be required in the GIPS 2020 standards we would welcome further guidance on this. Request for Comment #21 In GIPS 2010, compliant presentations for private equity composites and closed-end real estate funds are required to include certain information about committed capital, distributions, and related multiples as of each annual period end. For example, a private equity composite that has been in existence for four years would present four series of information about committed capital, distributions, and related multiples. Consistent with the proposed change to require firms to present only one return the since-inception money-weighted return through the most recent annual period end we require information about committed capital, distributions, and related multiples as of the most recent annual period end. Do you agree that firms should be required to present information about committed capital, distributions, and related multiples only as of the most recent annual period end? Answer AXA IM: Again we believe that there may be commitment-based structures that present TWR s and for TWR based there is no such requirement at all. Furthermore we believe that for such structures composite or pooled fund returns presented should be without committed capital, thus only based on invested capital. And in that case we neither think that the requirement to present information about committed capital or distributions is of value for recipients of such a report. Request for Comment #22 Once a firm obtains standalone portfolios that are managed in the same strategy as the carve-out with allocated cash, the firm must create a composite that includes only standalone portfolios and must present the performance of the composite of standalone portfolios along with the performance of the composite that includes portfolios with allocated cash. The composite that includes carve-outs with allocated cash will have a different inception date from the composite of standalone portfolios. Do since-inception money-weighted returns with different start dates provide helpful information to prospective clients? Answer AXA IM: We generally disagree with the requirement to maintain two separate composites, one including carve-outs of the same strategy and one only consisting of the standalone portfolios for such a strategy. Therefore we suggest refraining from this requirement which would make this provision obsolete as well. We do not see added value for prospective clients from this. Request for Comment #23 We frequently hear that too many disclosures are required in GIPS reports. We have introduced sunset provisions where possible that is, although all disclosures must be included for at least one year, some disclosures may Seite 9 / 17

10 subsequently be deleted once the firm determines that they are no longer relevant to interpreting the performance track record. Do you agree that firms should be allowed to delete some disclosures once the firm determines that they are no longer relevant to interpreting the performance track record? Did we correctly identify the disclosures that should be allowed to be deleted once the firm determines that they are no longer relevant to interpreting the performance track record? Answer AXA IM: Yes, we welcome this new sunset provision. Former changes to the minimum asset level, as well as past firm or composite redefinitions should also fall under this provision. Further we suggest to also request (and de facto allow) that if a public market equivalent or alike (i.e. a peer group median) is presented as a benchmark not only for MWR based composite reports but also for TWR based composites this is appropriately being disclosed including the methodology. Request for Comment #24 Investors in a pooled fund will be impacted by all fees and costs incurred by the fund. Therefore, we require firms to present pooled fund returns that are net of all fees and expenses. Do you agree the firms should be required to present pooled fund returns that are net of all fees and expenses? Answer AXA IM: Yes we agree. Request for Comment #25 In GIPS 2010, firms are required to present income and capital component returns for real estate composites. When calculating these component returns, firms are required to calculate each component return separately. As part of the move to eliminate asset class provisions, we have deleted these real estate specific requirements and have expanded the concept of component returns to all composites and pooled funds. Firms would be allowed to derive one of the component returns as the difference between the total return and one of the calculated component returns. We acknowledge that component returns are widely used in some markets but not in others. We therefore are recommending component returns to be included in GIPS Composite and Pooled Fund Reports that include time-weighted returns, and we expect that firms will present component returns where it is customary for a specific market to do so. Do you agree with eliminating the requirement for real estate portfolios to present component returns? Do you agree with eliminating the requirement for real estate portfolios to separately calculate component returns? Do you agree that component returns should be recommended for all composites and pooled funds when timeweighted returns are presented? Answer AXA IM: Yes we agree with the removal of the requirement for real estate portfolios to present component returns and to calculate them separately. We do not see why the recommendation to present component returns should be limited to TWR based reports only. And since this recommendation indeed would not intuitively concern most of the asset classes we rather suggest recommending to present component returns when it is customary for the specific market to do so, or, if this is too generic, to refrain from the recommendation at all. Request for Comment #26 We frequently hear that too many disclosures are required in GIPS reports. We have introduced sunset provisions where possible that is, although all disclosures must be included for at least one year, some disclosures may subsequently be deleted once the firm determines that they are no longer relevant to interpreting the performance track record. Do you agree that firms should be allowed to delete some disclosures once the firm determines that they are no longer relevant to interpreting the performance track record? Did we correctly identify the disclosures that should be allowed to be deleted once the firm determines that they are no longer relevant to interpreting the performance track record? Answer AXA IM: Yes, we agree to include a sunset provision that allows removing certain disclosures over time. And we believe the disclosures that should be allowed to be removed after a certain time have been correctly identified. Request for Comment #27 In GIPS 2010, compliant presentations for private equity composites and closed-end real estate funds are required to include since-inception internal rates of return (now renamed money-weighted returns) through each annual period end. For example, a private equity composite that has been in existence for four years would present four since-inception money-weighted returns. We propose to instead require firms to present moneyweighted returns for only one period: from the pooled fund s inception through the most recent annual period Seite 10 / 17

11 end. Also, investors in a pooled fund will be impacted by all fees and costs incurred by the fund. Therefore, we require firms to present pooled fund returns that are net of all fees and expenses. Do you agree that firms should be required to present returns for only one period from inception through the most recent annual period end? Do you agree the firms should be required to present pooled fund returns that are net of all fees and expenses? Answer AXA IM: No, we disagree with the requirement to only present returns for a single period (ITD). We see no reason why not also for pooled funds presenting MWR s at least annual returns should be required, same as for funds presenting TWR s. With the calculation means available to firms it is certainly possible to calculate annual MWR s and not only inception to date MWR s. We agree though with the requirement to present net of fees MWR s, in line with the same requirement for funds presenting net TWR s. Request for Comment #28 Subscription lines of credit are being used by more firms and for longer periods. These lines of credit can have a significant effect on returns. As has been widely discussed in the industry, there has also been a lack of consistency in return calculations when lines of credit are used. For comparability and transparency, we propose requiring firms to present returns both with and without the subscription line of credit activity, whenever any line of credit has been used. A return with the line of credit reflects line of credit activity as an external cash flow. Do you agree that firms should be required to present returns both with and without the subscription line of credit activity? Should we be describing returns with and without the subscription line of credit differently? For example, some firms refer to these returns as levered and unlevered returns. Do you agree that firms should be required to treat all lines of credit the same and not differentiate between short-term and long-term lines of credit? We propose requiring returns with and without the subscription line of credit activity only when money-weighted returns are presented. There is no comparable requirement when time-weighted returns are presented. Do you agree that this is the correct approach? Answer AXA IM: We do not like the requirement to present two sets of performances for the same pooled fund. At the end there is only one return for the investor, the one over the invested portfolio. Some firms may present commitment based products that facilitate a credit line to invest the portfolio first and then to call the capital, whilst others present a fund that uses systematic leverage, and others won t use any of these techniques. Also we do not agree with the limitation of the requirement to funds that present MWR s only. This should be handled consistently, regardless what type of return is being presented. We therefore suggest requiring firms that use any sort of credit or leverage facilities to present return including the effect of such techniques (and if a return without credit lines should be presented, what is the requirement to calculate this in order to ensure consistency across firms?). Request for Comment #29 In GIPS 2010, compliant presentations for private equity composites and closed-end real estate funds are required to include certain information about committed capital, distributions, and related multiples as of each annual period end. For example, a private equity composite that has been in existence for four years would present four series of information about committed capital, distributions, and related multiples. Consistent with the proposed change to require firms to present only one return the since-inception money-weighted return through the most recent annual period end we require information about committed capital, distributions, and related multiples as of the most recent annual period end. Do you agree that firms should be required to present information about committed capital, distributions, and related multiples only as of the most recent annual period end? Answer AXA IM: We believe that there may be commitment-based structures that present TWR s and for TWR based reports there is no such requirement at all. Furthermore we believe that for such structures composite or pooled fund returns presented should be without committed capital, thus only based on invested capital. And in that case we neither think that the requirement to present information about committed capital or distributions is of value for recipients of such a report. Request for Comment #30 We frequently hear that too many disclosures are required in GIPS reports. We have introduced sunset provisions where possible that is, although all disclosures must be included for at least one year, some disclosures may subsequently be deleted once the firm determines that they are no longer relevant to interpreting the performance track record. Seite 11 / 17

12 Do you agree that firms should be allowed to delete some disclosures once the firm determines that they are no longer relevant to interpreting the performance track record? Did we correctly identify the disclosures that should be allowed to be deleted once the firm determines that they are no longer relevant to interpreting the performance track record? Answer AXA IM: Yes, we agree to include a sunset provision that allows removing certain disclosures over time. And we believe the disclosures that should be allowed to be removed after a certain time have been correctly identified. Request for Comment #31 Currently, the GIPS standards are silent on how quickly asset owners must update GIPS-compliant presentations. (For Asset Owners, the term compliant presentation has been replaced with GIPS Asset Owner Report.) Although we have not seen this happen with asset owners, some firms present returns that are several years old, often providing as the rationale the fact that they are waiting for the verification to be completed before updating the reports. We believe that firms and asset owners should be required to update GIPS reports on a timely basis, even if the verification is not complete. Do you agree that asset owners should be required to update GIPS reports within a specified time period? Do you agree that six months is the appropriate amount of time? Answer AXA IM: We agree that GIPS reports shall be updated within a specific time period whilst we suggest requiring at least an annual update rather than every six months. Request for Comment #32 Consistent with the Guidance Statement on the Application of the GIPS Standards to Asset Owners, if an asset owner has the authority to compete for business by marketing to prospective clients, as is done by firms, the part of the asset owner that is competing for assets must be defined as a separate firm. This separate firm must follow all sections of the GIPS standards related to firms and all applicable requirements. Do you agree that this concept should continue? Answer AXA IM: Yes we agree. In fact many of the entities listed under the Asset Owner definition may in compete for business. Therefore this must be a strict requirement that in such circumstances the Asset Owner identifies itself or the part of the firm that does compete for business as a classical GIPS firm and must fulfill all those requirements. Request for Comment #33 Asset owners may choose to present time-weighted returns or money-weighted returns for additional composites. Do you agree that asset owners should be allowed to choose which returns are presented for the optional additional composites? Answer AXA IM: We do not really understand why the Asset Owner per se (based on the types of assets it owns) may not choose to present either TWR s or MWR s. We don t think Asset Owners per definition control the cash flows into their total fund. And as proposed, if they present optional additional composites they should be able to choose as well. Request for Comment #34 Currently, all returns must be calculated after the deduction of actual trading expenses incurred during the period, and estimated trading expenses are not allowed. When the GIPS standards were originally created, trading expenses were generally higher than they are now and were more standardized. Today, trading expenses can be charged in a variety of ways and may not be under an asset owner s control. Indeed, in some instances, asset owners may not have the ability to determine how or where trading expenses are charged. We have decided to introduce allowing estimated transaction costs (the term that replaces trading costs) if returns calculated using estimated transaction costs are equal to or lower than those that would have been calculated using actual transaction costs. Do you agree that estimated transaction costs should be allowed? Do you believe that asset owners will have the ability to determine if estimated transaction costs are more conservative than actual transaction costs? Answer AXA IM: We believe that the test whether estimated transaction costs are equal or higher than actual trading costs will be hard to be made. As such we have no objection against allowing estimated trading cost but we recommend to precise that an estimate is only possible when the actual costs are unknown or not directly observable to the Asset Owner. And instead of the test Asset Owners should rather disclose the approach they have chosen to estimate these costs. Request for Comment #35 The Guidance Statement on Alternative Investment Strategies and Structures provides guidance for asset owners that manage alternative strategies if the asset owner places reliance on valuations that are received with a Seite 12 / 17