GLENMEDE. Question l: Do you agree with the pillars concept? If so, should there be any other pillars?

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1 June 19th, 2017 CFA Institute 915 E. High street Charlottesville, VA Re: GIPS Consultation Paper Thanks for the opportunity to comment on the GIPS 2020 Consultation Paper. Listed below are the responses to each question posed in the paper. We also provided some additional information outside of the thirteen questions presented in the guidance statement. Question l: Do you agree with the pillars concept? If so, should there be any other pillars? The pillars concept is a good idea to allow additional types of firms to claim GIPS compliance. An additional pillar should be around OCIO firms who only sub-advise on the assets and do not actively manage each portfolio. Question 2: Do you agree with the proposed treatment of pooled funds? We tend to disagree with this treatment of pooled funds because of the complexity of the composite disclosure pages. If a firm only has a fund in a particular strategy but wants to market to individual clients, what would be presented? Under current guidance, a firm would be required to create a single-fund composite anyway. It seems that this rule only applies to firms that only have pooled funds and never intend to market to individual clients. Question 3: Do you agree that asset-class-specific guidance should be consolidated where possible? Yes, asset class specific guidance should be limited in scope within the GIPS standards. Real Estate and Private Equity guidance should be combined and the differences between the two should be consolidated to provide guidance for these alternative assets. Question 4a: Do you agree with the proposal that firms should be allowed to choose whether to present IRRs or TWRRs for any closed-end, fixed life, fixed commitments fund where the firm controls the timing of the cash flows? Yes, firms should be able to decide to use either TWRR's or IRR's based upon the assets. This will allow easier comparison amongst various assets classes by the end investors for their analysis. Additional guidance needs to be drafted to address how to calculate performance returns where the account holds both assets where TWRR is appropriate and assets where IRR is appropriate Market Street. Suite 1200 Philadelphia. PA

2 Question 4b: What criteria should be required for a firm to be allowed to present an IRR versus TWRR? The main criteria that should be used would be who controls the cash flows, whether it is the asset management firm or the end investor. Another criteria that should be considered is the valuation of the underlying assets. If the underlying assets are only valued monthly or quarterly, that will impact the return differences between the time weighted methodology and the money weighted methodology. Question 5a: For calculating TWRR, do you believe that valuing monthly and at the time of all large cash flow suffices? Yes, this will be sufficient for the standard but daily valuation and calculation should be the recommendation. More guidance on what is deemed 'large cash flow" would be appreciated. Historically, a 'large cash flow' was around a ten percent tolerance but additional guidance for the term 'large cash flow' would help for the guidance of the tolerance range. Question 5b: For calculating IRR, do you agree with the proposed valuation frequency for all portfolios regardless of the underlying investment or asset class? We agree that the minimum valuation period should be a year for all assets that would have IRR's calculated. For the point to point or since inception IRR calculation, the valuation should be on the last day of the performance calculation. ' Question 6a: Do you agree that firms should be required to provide a pooled fund report to investors in the pooled fund on an annual basis? No, firms should not be required to provide fund investors with a report specific to GIPS on an annual basis. With the US, mutual funds are required to provide annual reports to the end investors in a fund. We feel that the current mutual fund annual reports are sufficient to meet the end investor's needs. Question 6b: Do you agree that firms should be required to provide a compliant presentation to existing clients in the composite on an annual basis? No, Firms should only be required to provide contact information about how to obtain a compliant presentation from the firm. Providing all of the end investors with a GIPS compliant presentation would burden investment management firms with additional record keeping and client lists. Also, if a client is only in the composite for one month out of twelve, would they still need to receive a compliant presentation? For firms that provide wrap accounts, this would require additional client documentation and contact information by the firm managing the assets. This would be additional work by many firms which will not benefit the end client because they already receive their performance reports and can ask the account manager for additional information. Question 6c: Do you agree that firms should be required to make an offer to provide a composite compliant presentation or pooled fund report to existing clients or pooled fund investors on an annual basis? 1650 Market Street, Suite1200 Philadelphia, PA

3 Yes, if the investment management firm provides information on their website about the composite that should suffice for this recommendation. However, if there is any additional record keeping or client contact lists, this should not be required. Our opinion is to make the process simpler and not add additional record keeping requirements to the GIPS standards. Question 7a: Do you agree with creating a new category of assets as described above? Question 7b: Which assets should be included in this new category of assets (e.g., UMAs, models, overlay, and advisory-only portfolios)? Question 7c: Should firms be recommended or required to report this new category of assets as well as total firm assets in compliant presentations? With all three of these questions, we feel that the model, UMA, overlay, and advisory only assets should not be part of the overall firm assets for GIPS. For some of these types of assets, the asset manager does not have full discretion over them and therefore should be excluded from the overall firm's assets. This should be a recommendation only to allow firms to create/report this new category if they choose. Question Ba: Do you agree with no longer allowing firms to exclude non-fee-paying portfolios from composites based solely on fee-paying status? Yes, non-fee paying accounts should be included in the composites if they are in the same strategy. Whether or not the account pays a fee should have no bearing on the inclusion in the composite. Question Bb: How should non-fee-paying portfolios be treated for net-of-fees calculations? If a composite includes a non-fee paying portfolio, then the fee schedule should apply to the entire composite. If you want to use the actual fees of the accounts in the composite, then the appropriate fee for that account should be applied to non-fee paying account. If there is any question about what fee should be used for the account, then the highest applicable fee should be used based upon the fee schedule. Question 9: Do you agree that firms should have more flexibility to state that the firm complies with the GIPS standards? Yes, firms should be allowed to use the claim of compliance on additional marketing materials and the firm's website if they abide by the standards and have a current external verification within the past 24 months. The GIPS logo should also be allowed in marketing materials with less restrictions than the current process. This would allow the GIPS standards to be more wellknown and accepted by the end investors. Question loa: Do you agree with requiring firms to update compliant presentations on a timely basis? Question lob: How current should the information be required to be in a compliant presentation? Yes, firms should be required to update the compliant presentations at least once a year. This will allow the end investors and prospects to see current information and not rely on old stale The Glenmede Trust Company, N.A Market Street, Suite 1200 Philadelphia, PA

4 data to make an investment decision. A recommendation should also be to update the composite disclosure on a quarterly basis to provide the most up to date information. Question J J: Do you agree with allowing firms to use estimated trading expenses? Yes, estimated trading expenses can be used for GIPS compliance as long as they are fully disclosed. Additional language would also need to be required to explain how the estimated trading expenses are calculated and if there are any changes to the estimates, then they must also be shown in the compliant presentation. Question J 2a: Which existing numerical information and disclosure requirements, if any, should be removed? The three year ex-post standard deviation should be removed from the composite disclosure page. This information does not provide any additional commentary to the end investor for certain asset classes such as cash equivalents or left tail skewed alternative assets. The carve-out information should also be removed from the composite presentation since it is now over 5 years since carve outs can be used within the standards framework. For real estate and private equity, the following items should no longer be required: Total value to since inception paid in capital, since inception distributions to since inception paid in capital, since inception paid in capital to cumulative committed capital, and residual value to since inception paid in capital because these types of ratios are not required on marketable assets and the GIPS standards should remain similar amongst all asset classes. For periods prior to 2000 that are not in compliance with the standards, this requirement should be removed from the composite disclosure. The firm should still be required to have this in the policy and procedures of the firm but after 17 years, there is no reason that it should be shown on the disclosure page. The composite creation date should also be removed from the presentation. This information can be maintained in the firm's composite system and provided upon request but does not add value to the investment decision making process. Question 12b: Is there any information not currently required that should be required in compliant presentations? In the compliant presentation, the physical location of the portfolio managers and offices of the firm should be shown in the presentation. The requirement should be only the country of the portfolio managers, analysts, and traders but the recommendation would be the city and state or municipality. Question 12e: Are there any disclosures that can be discontinued after a certain period-of-time? Yes, the significant events should only need to be disclosed for the previous three years since historical changes to portfolio managers beyond that timeframe adds little to the investment decision making process. Also, the name change of the composite should also have a three year time horizon on it as well Market Street, Suite1200 Philadelphia, PA

5 In general, all information that changed on the composite should only be shown on the compliant presentation for the past three to five years but still remain in the policies and procedures of the firm indefinitely. Question 13: Are there other issues that are important for us to address as part of the GIPS 20/20 project? Our main issue with the standards are that currently there is no guidance for high net worth firms with both Private Equity and marketable assets to calculate returns to maintain compliance with the standards. There is guidance for IRR's for private equity and Time weighted calculations for the marketable assets but nothing on how to create composites with balanced accounts that include Private Equity, Real estate, and marketable assets. This has been a major roadblock in allowing high net worth asset managers to claim compliance with the GIPS standards. Another area that should be addressed by the project would be verification firms that have clients that have fraudulent activities that are not found but should have been discovered during the GIPS verification or examination. These firms should be barred from performing GIPS verifications or examinations for a specific period of time and have a review of their procedures immediately by the CFA Institute. A process should be setup similar to the PCAOB (Public Company Accounting Oversight Board) for review if there are issues relating to a GIPS verification or examination. Please contact us with any questions or concerns on the comments. Thanks! Maureen Fioravanti, CIPM Jason H. Pearl, CIPM Michael F. Beck, CIPM 1650 Market Street, Suite 1200 Philadelphia, PA