VBA-Beroepsvereniging van Beleggingsprofessionals

Transcription

1 CFA Institute Centre for Financial Market Integrity Reference: Global Investment Performance Standards P.O. Box 3668 Charlottesville, Virginia FAX: Amsterdam, 8 July 2009 Dear EC members, We hereby send you the response of the VBA-IPM Committee, the Dutch Investment Performance Measurement Committee of VBA, the local sponsor of GIPS in the Netherlands, regarding GIPS For questions and/or comments, please do not hesitate to contact the following individuals: Mark van Eijk Chairman, VBA-IPM Committee, mark.van.eijk@nl.pwc.coml Hans Braker, Secretary, VBA-IPM Committee, hans.braker@cs.com Kind regards, Mark van Eijk Chairman, VBA-IPM Page 1 of 62

2 0. FUNDAMENTALS OF COMPLIANCE 0.A Definition of the Firm Requirements 0.A.1 The GIPS standards MUST be applied on a FIRM-wide basis. 0.A.2 FIRMS MUST be defined as an investment firm, subsidiary, or division held out to clients or PROSPECTIVE CLIENTS as a DISTINCT BUSINESS ENTITY. 0.A.3 1 TOTAL FIRM ASSETS MUST be the aggregate of the FAIR VALUE of all discretionary and nondiscretionary assets under management within the FIRM. This includes both fee-paying and non-feepaying PORTFOLIOS. 0.A.4 FIRMS MUST include the performance of assets assigned to a SUB-ADVISOR in a COMPOSITE provided the FIRM has discretion over the selection of the SUB- ADVISOR. 0.A.5 Changes in a FIRM S organization MUST NOT lead to alteration of historical COMPOSITE performance. Please remove the last sentence to the footnote or the glossary definition because it does not add anything substantial to the provision. Besides that, we agree We do not approve of changing results to performance. In some countries, the word performance has different meanings. In order of preference we would like: 1) Keep using the wording results 2) Change results to records 3) Change results to performance and add a glossary definition of performance. We agree with the other changes. We especially like the more consistent syntax, for example the consistent use of MUST NOT and SHOULD. 0.B Definition of the Firm Recommendations 0.B.1 FIRMS SHOULD adopt the broadest, most meaningful definition of the FIRM. The scope of this definition SHOULD include all geographical (country, regional, etc.) offices operating under the same brand name regardless of the actual name of the individual investment management company. 1 For periods beginning prior to 1 January 2011, TOTAL FIRM ASSETS MUST be the aggregate of the MARKET VALUE of all discretionary and nondiscretionary assets under management within the defined FIRM. Page 2 of 62

3 0.A Document Policies and Procedures Requirements 0.A.6 FIRMS MUST document their policies and procedures used in establishing and maintaining compliance with the GIPS standards. We like the change from compliance with all the applicable REQUIREMENTS of the GIPS standards to just compliance with the GIPS standards. This gives a strong message that FIRMS are not allowed to be in compliance with only those standards that they consider applicable, but are required to be in compliance with the standards as a whole. 0.A Claim of Compliance Requirements 0.A.7 Once a FIRM has met all applicable REQUIREMENTS of the GIPS standards, the FIRM MUST use one of the following compliance statements to indicate that the FIRM is in compliance with the GIPS standards. The compliance statement MUST remain in a single paragraph. For FIRMS that are currently verified: We would like to delete the words all applicable REQUIREMENTS of, So the provision would become: Once a FIRM has met the GIPS standards,. This would be stronger and more consistent with 0.A.6. We agree with the other changes. that the firm must include the verified period. Text currently verified is confusing and does not give any additional information when the verified period has already been disclosed. We therefore propose to delete the second option not currently verified (and as a consequence also propose to delete the definition of current ) We would like a firm to have only two options: state the verified period or state that the firm has not been independently verified. We agree with the changes regarding these two options. [Insert name of FIRM] claims compliance with the Global Investment Performance Standards (GIPS ) and has prepared and presented this report in compliance with the GIPS standards. [Insert name of FIRM] has been independently verified for the periods [insert dates]. A copy of the VERIFICATION REPORT(S) is/are available upon request. Idem. Page 3 of 62

4 For FIRMS that have been verified, but are not currently verified: [Insert name of FIRM] claims compliance with the Global Investment Performance Standards (GIPS ) and has prepared and presented this report in compliance with the GIPS standards. [Insert name of FIRM] has been independently verified for the periods [insert dates]. The FIRM is not currently independently verified. For purposes of this provision, a VERIFICATION is considered current if the VERIFICATION REPORT covers a period ending not more than 24 months ago. For FIRMS that have not been verified: [Insert name of FIRM] claims compliance with the Global Investment Performance Standards (GIPS ) and has prepared and presented this report in compliance with the GIPS standards. [Insert name of FIRM] has not been independently verified. Idem. Idem. Idem. Idem. Idem. Do you agree with including disclosure of the firm s verification status in the claim of compliance? Yes Do you agree with the classification of a current verification being within the last 24 months? No 0.A.8 If the FIRM does not meet all applicable REQUIREMENTS of the GIPS standards, the FIRM MUST NOT represent that it is in compliance with the Global Investment Performance Standards except for..., or other statements that may indicate partial compliance with the GIPS standards. 0.A.9 Statements referring to the calculation methodology used in a performance presentation as being in accordance, in compliance, or consistent with the Global Investment Performance Standards, or similar statements are prohibited. We would like to delete the words all applicable REQUIREMENTS of, So the provision would become: If the FIRM does not meet the GIPS standards,. This would be stronger and more consistent with 0.A.6. We agree with the other changes. Please include a definition in the glossary of performance presentation. Without a clear definition, this wording is confusing. For example, is an annual report a performance presentation? We furthermore want to ask for more clarification for situations when local laws require you to state that a certain calculation is in accordance with GIPS? In the Netherlands, this situation arises from the local laws on the z-score. We agree with the other changes. Page 4 of 62

5 0. A.10Statements referring to the performance of a single, existing client PORTFOLIO as being calculated in accordance with the Global Investment Performance Standards are prohibited except when a GIPS-compliant FIRM reports the performance of an individual client s PORTFOLIO to that client. In the Exposure Draft, the word PORFOLIO is used instead of PORTFOLIO. Please correct. (or include a definition of PORFOLIO ). Besides this, we agree 0.A Firm Fundamental Responsibilities Requirements 0.A.11 FIRMS MUST make every reasonable effort to provide a COMPLIANT PRESENTATION to all PROSPECTIVE CLIENTS. FIRMS MUST NOT choose to whom they want to present compliant performance. As long as a PROSPECTIVE CLIENT has received a COMPLIANT PRESENTATION within the previous 12 months, the FIRM has met this REQUIREMENT. Please add clarification how compliance with this provision should be verified. Please clarify previous 12 months. Is this the 12 month period directly preceding the end of the verification period? Or is this the 12 month period preceding the calendar date that the verifier started with the verification? Or another 12 month period? Please add clarification on the impact of noncompliance, i.e. what to do if a firm did not make every reasonable effort for a certain period? And what to do if the firm, in addition to not making every reasonable effort, did not record/remember all prospective clients? 0.A.12 FIRMS MUST provide a complete list and description of the FIRM S COMPOSITES to any existing or PROSPECTIVE CLIENT that makes such a request. FIRMS MUST list closed COMPOSITES on the FIRM S list of COMPOSITES for at least 5 years after closure. 0.A.13 FIRMS MUST provide a COMPLIANT PRESENTATION for any COMPOSITE listed on the FIRM S list and description of COMPOSITES to any existing or PROSPECTIVE CLIENT that makes such a request. 0.A.14 When the FIRM jointly markets with other firms, the FIRM claiming compliance with the GIPS standards MUST be sure that it is clearly defined and separate relative to other firms being marketed and that it is clear which FIRM is claiming compliance. Besides this, we agree We refer to our comments on 0.A.11. Besides this, we agree Page 5 of 62

6 0.A.15 FIRMS MUST comply with all applicable REQUIREMENTS of the GIPS standards, including any updated information, Guidance Statements, interpretations, Questions & Answers (Q&As), and clarifications published by CFA Institute and the GIPS Executive Committee, which will be made available via the GIPS website ( as well as the GIPS Handbook. 0.A.16 FIRMS MUST comply with all applicable laws and regulations regarding the calculation and reporting of returns. 0.A.17 FIRMS MUST NOT present performance or performance related information that is false or misleading. We would like to delete the words all applicable REQUIREMENTS of, So the provision would become: FIRMS MUST comply with the GIPS standards,. This would be stronger and more consistent with 0.A.6. We furthermore object to including text on the GIPS Handbook. The GIPS standards should be freely available and no profit should be made by requiring firms to purchase handbooks. Besides this, we agree Considering the importance of this provision, we propose to make it one of the first provisions rather than the 16 th. Besides this, we agree Please consider removing this provision, because in general provision 0.A.16 makes this provision redundant. Please add deliberately before present and add materially before false. Besides this, we agree 0.B Firm Fundamental Responsibilities - Recommendations 0.B.2 FIRMS SHOULD provide to each existing client, on an annual basis, a COMPLIANT PRESENTATION for the COMPOSITE(S) in which the client s PORTFOLIO is included. 0.B.3 FIRMS SHOULD comply with the RECOMMENDATIONS of the GIPS standards, including RECOMMENDATIONS included in any updated information, Guidance Statements, interpretations, Questions & Answers (Q&As), and clarifications published by CFA Institute and the GIPS Executive Committee, which will be made available via the GIPS website ( as well as the GIPS Handbook. 0.B. 4 FIRMS SHOULD be verified. Please delete this provision as it is redundant. By using the word RECOMMENDATION and SHOULD it is already clear that firms should comply with the recommendation. We furthermore object to including text on the GIPS Handbook. The GIPS standards should be freely available and no profit should be made by requiring firms to purchase handbooks. Page 6 of 62

7 1. INPUT DATA 1.A Input Data Requirements 1.A.1 All data and information necessary to support all items included in a COMPLIANT PRESENTATION MUST be captured and maintained. 1.A.2 2 For periods beginning on or after 1 January 2011, PORTFOLIOS MUST be valued at FAIR VALUE in accordance with the GIPS Valuation Principles in Appendix D. Do you agree with the change from market value to fair value? YES 1.A.3 3 FIRMS MUST value PORTFOLIOS in accordance with the COMPOSITE specific valuation policy. PORTFOLIOS MUST be valued: a) At least monthly. b) On the date of all LARGE CASH FLOWS. c) No more frequently than required by Please explain why provision C has been added? the valuation policy. 1.A.4 For periods beginning on or after 1 January 2010, FIRMS MUST value PORTFOLIOS as of the calendar monthend or the last business day of the month. 1.A.5 For periods beginning on or after 1 January 2005, FIRMS MUST use TRADE DATE ACCOUNTING. 1.A.6 ACCRUAL ACCOUNTING MUST be used for fixed-income securities and all other investments that accrue interest income. The FAIR VALUE of fixed-income securities MUST include accrued income. 1.A.7 For periods beginning on or after 1 January 2006, COMPOSITES MUST have consistent beginning and ending annual valuation dates. Unless the COMPOSITE is reported on a non-calendar fiscal year, the beginning and ending valuation dates MUST be at calendar year-end or on the last business day of the year. We agree but think that the first sentence is redundant since it can be integrated with the second sentence. Please rephrase the second as follows: The fair value of investments must include accrued income 2 For periods beginning prior to 1 January 2011, PORTFOLIO valuations MUST be based on MARKET VALUES (not cost basis or book values). 3 For periods beginning prior to 1 January 2001, PORTFOLIOS MUST be valued at least quarterly. For periods beginning on or after 1 January 2001, PORTFOLIOS MUST be valued at least monthly. For periods beginning on or after 1 January 2010, FIRMS MUST value PORTFOLIOS on the date of all LARGE CASH FLOWS. Page 7 of 62

8 1.B Input Data Recommendations 1.B.1 FAIR VALUES SHOULD be obtained from a qualified independent external third party. 1.B.2 ACCRUAL ACCOUNTING SHOULD be used for dividends (as of the ex-dividend date). 1.B.3 When presenting NET-OF-FEES RETURNS, FIRMS SHOULD accrue INVESTMENT MANAGEMENT FEES. 1.B.4 FIRMS SHOULD value PORTFOLIOS on the date of all EXTERNAL CASH FLOWS. 2. CALCULATION METHODOLOGY 2.A Calculation Methodology Requirements 2.A.1 TOTAL RETURNS MUST be used. 2.A.2 4 TIME-WEIGHTED RATES OF RETURN that adjust for EXTERNAL CASH FLOWS MUST be used. Periodic returns MUST be geometrically LINKED. EXTERNAL CASH FLOWS MUST be treated in a consistent manner with the FIRM S documented, COMPOSITE-specific policy. FIRMS MUST define LARGE CASH FLOW for each COMPOSITE to determine when the PORTFOLIOS in that COMPOSITE are to be revalued for calculating performance. 2.A.3 COMPOSITE returns MUST be calculated by asset weighting the individual PORTFOLIO returns using beginning-ofperiod values or a method that reflects both beginning-of-period values and EXTERNAL CASH FLOWS. 2.A.4 Returns from cash and cash equivalents held in PORTFOLIOS MUST be included in TOTAL RETURN calculations. 2.A.5 All returns MUST be calculated after the deduction of the actual TRADING EXPENSES incurred during the period. FIRMS MUST NOT use estimated TRADING EXPENSES. 2.A.6 5 For periods beginning on or after 1 January 2010, COMPOSITE returns MUST be calculated by asset weighting the individual PORTFOLIO returns at least monthly. 4 For periods beginning on or after 1 January 2005, FIRMS MUST use approximated rates of return that adjust for daily-weighted EXTERNAL CASH FLOWS. For periods beginning on or after 1 January 2010, FIRMS MUST value PORTFOLIOS on the date of all LARGE EXTERNAL CASH FLOWS. 5 For periods beginning on or after 1 January 2006, FIRMS MUST calculate COMPOSITE returns by asset weighting the individual PORTFOLIO returns at least quarterly, Page 8 of 62

9 a) When calculating GROSS-OF-FEES RETURNS, returns MUST be reduced by the entire BUNDLED FEE or the portion of the BUNDLED FEE that includes the direct TRADING EXPENSES. FIRMS MUST NOT use estimated TRADING EXPENSES. b) When calculating NET-OF-FEES RETURNS, returns MUST be reduced by the entire BUNDLED FEE or the portion of the BUNDLED FEE that includes the direct TRADING EXPENSES and the INVESTMENT MANAGEMENT FEE. FIRMS MUST NOT use estimated TRADING EXPENSES. 2.B Calculation Methodology Recommendations 2.B.1 Returns SHOULD be calculated net of non-reclaimable withholding taxes on dividends, interest, and capital gains. Reclaimable withholding taxes SHOULD be accrued. 3. COMPOSITE CONSTRUCTION 3.A Composite Construction Requirements 3.A.1 6 All actual discretionary PORTFOLIOS MUST be included in at least one COMPOSITE. Nondiscretionary PORTFOLIOS MUST NOT be included in a FIRM S COMPOSITES. Do you agree with requiring the inclusion of non-fee paying discretionary portfolios in composites? 3.A.2 COMPOSITES MUST be defined according to similar investment objectives and/or strategies. COMPOSITES MUST include all PORTFOLIOS that meet the COMPOSITE DEFINITION. The full COMPOSITE DEFINITION MUST be made available on request. 3.A.3 COMPOSITES MUST include new PORTFOLIOS on a timely and consistent basis after the PORTFOLIO comes under management. 6 For periods beginning prior to 1 January 2011, all actual, fee-paying, discretionary PORTFOLIOS MUST be included in at least one COMPOSITE. Page 9 of 62

10 3.A.5 PORTFOLIOS MUST NOT be switched from one COMPOSITE to another unless documented changes in client guidelines or the redefinition of the COMPOSITE make it appropriate. The historical record of the PORTFOLIO MUST remain with the appropriate COMPOSITE. 3.A.6 7 For periods beginning on or after 1 January 2010, CARVE-OUTS MUST NOT be included in COMPOSITES unless the CARVE-OUT is actually managed separately with its own cash balance. 3.A.7 COMPOSITES MUST include only assets under management within the defined FIRM. FIRMS MUST NOT LINK simulated or model PORTFOLIOS with actual performance. 3.A.8 If a FIRM sets a minimum asset level for PORTFOLIOS to be included in a COMPOSITE, FIRMS MUST NOT include PORTFOLIOS below that asset level in that COMPOSITE. Any changes to a COMPOSITE-specific minimum asset level MUST NOT be applied retroactively 3.A.9 FIRMS MUST NOT present a COMPOSITE to a PROSPECTIVE CLIENT known to have a PORTFOLIO with assets less than the COMPOSITE S minimum asset level. Please explain why the old standard 3.A.6 has been removed? Besides this we agree Please remove the text within the defined. Besides this we agree. We think that this provision should stay as recommendation. Besides this we agree. Do you agree with changing 3.A.9 from a recommendation to a requirement? No 3.A.10 FIRMS that wish to remove PORTFOLIOS from COMPOSITES in cases of SIGNIFICANT CASH FLOWS MUST define significant on an EX-ANTE COMPOSITE-specific basis and MUST consistently follow the COMPOSITEspecific SIGNIFICANT CASH FLOW policy. 3.B Composite Construction Recommendations 3. B.1 To remove the effect of a SIGNIFICANT CASH FLOW, FIRMS SHOULD use TEMPORARY NEW ACCOUNTS. 7 For periods beginning prior to 1 January 2010, if CARVE-OUTS are included in a COMPOSITE, cash MUST be allocated to the CARVE-OUT in a timely and consistent manner. Page 10 of 62

11 4. DISCLOSURE 4.A Disclosures Requirements Should firms be allowed to remove certain disclosures after a defined period of time? If so, which disclosures would be eligible for removal and after what period of time? YES 4.A.1 FIRMS MUST disclose the definition of FIRM used to determine the TOTAL FIRM ASSETS and FIRM-wide compliance. 4.A.2 FIRMS MUST disclose the availability of a complete list and description of the FIRM S COMPOSITES. 4.A.3 FIRMS MUST disclose the minimum asset level, if any, below which PORTFOLIOS are not included in a COMPOSITE. FIRMS MUST also disclose any changes to the minimum asset level. 4.A.4 FIRMS MUST disclose the currency used to express performance. 4.A.5 FIRMS MUST disclose the presence, use, and extent of leverage, derivatives and/or short positions, if material, including a description of the frequency of use and characteristics of the instruments sufficient to identify risks. Please remove the word /or in the first sentence Besides this we agree. Do you agree with the inclusion of short positions in provision 4.A.5? YES 4.A.6 FIRMS MUST clearly label returns as GROSS-OF-FEES or NET-OF-FEES. 4.A.7 FIRMS MUST disclose relevant details of the treatment of withholding tax on dividends, interest income, and capital gains, if material. FIRMS MUST also disclose if BENCHMARK returns are net of withholding tax. 4.A.8 FIRMS MUST disclose and describe any known material differences in the exchange rates or valuation sources used among the PORTFOLIOS within a COMPOSITE and between the COMPOSITE and the BENCHMARK. 4.A.9 If the COMPLIANT PRESENTATION conforms with laws and regulations that differ from the REQUIREMENTS of the GIPS standards, FIRMS MUST disclose this fact and disclose the manner in which the laws and regulations conflict with the GIPS standards. Please add all to returns: clearly label all returns. Please delete: if material, this does not add anything since the provision already deals exclusively with relevant details. Page 11 of 62

12 4.A.11 For periods beginning prior to 1 January 2010, if CARVE-OUTS are included in a COMPOSITE, FIRMS MUST disclose the policy used to allocate cash to CARVE- OUTS. 4.A.12 FIRMS MUST disclose the FEE SCHEDULE appropriate to the COMPLIANT PRESENTATION. 4.A.13 If a COMPOSITE contains PORTFOLIOS with BUNDLED FEES, FIRMS MUST disclose for each annual period shown the percentage of COMPOSITE assets that is BUNDLED FEE PORTFOLIOS. 4.A.14 If a COMPOSITE contains PORTFOLIOS with BUNDLED FEES, FIRMS MUST disclose the various types of fees that are included in the BUNDLED FEE. 4.A.15 When presenting GROSS-OF-FEES RETURNS, FIRMS MUST disclose if any other fees are deducted in addition to the direct TRADING EXPENSES. 4.A.16 When presenting NET-OF-FEES RETURNS, FIRMS MUST disclose: a) If any other fees are deducted in addition to the INVESTMENT MANAGEMENT FEE and direct TRADING EXPENSES. b) If model or actual INVESTMENT MANAGEMENT FEES are used. c) If returns are net of PERFORMANCE BASED FEES. 4.A.17 FIRMS MUST disclose that information regarding policies for valuing PORTFOLIOS, calculating and reporting returns, and preparing COMPLIANT PRESENTATIONS is available upon request. 4.A.18 For periods beginning on or after 1 January 2006, FIRMS MUST disclose the use of a SUB-ADVISOR(S) and the periods a SUB-ADVISOR(S) was used. 4.A.19 FIRMS MUST disclose all significant events that would help a PROSPECTIVE CLIENT interpret the performance record. 4.A.20 FIRMS MUST disclose the COMPOSITE DESCRIPTION which must include sufficient information to allow a PROSPECTIVE CLIENT to understand the key characteristics of the COMPOSITE strategy, including risks. Please align all starting points to 1/1/2011 Please add: including sufficient details concerning performance based fees. a) Please change to: Please disclose all other fees that are deducted in addition to INVESTMENT MANAGEMENT FEE and direct TRADING EXPENSES. b) c) Please delete this provision. Performance based fees are included in the definition of investment management fees, so net-of-fees returns must always be net of performance based fees. Please add more guidance on key characteristics. This extra guidance can be in the GIPS handbook or Q&A. Please delete including risks. Page 12 of 62

13 Do you agree with requiring the disclosure of key characteristics and risks in the composite description? NO 4.A.21 If a FIRM is redefined, the FIRM MUST disclose the date, nature, and reason for the redefinition 4.A.22 If a FIRM has redefined a COMPOSITE, the FIRM MUST disclose the date, nature, and reason for the change. Changes to COMPOSITE DEFINITIONS MUST NOT be applied retroactively. 4.A.23 FIRMS MUST disclose any changes to the name of a COMPOSITE. 4.A.24 FIRMS MUST disclose the COMPOSITE CREATION DATE. 4.A.25 FIRMS MUST disclose if, for periods beginning prior to 1 January 2010, calendar month-end PORTFOLIO valuations or valuations on the last business day of the month are not used. 4.A.26 FIRMS MUST disclose which DISPERSION measure is presented. 4.A.27 If the FIRM has adopted a SIGNIFICANT CASH FLOW policy for a specific COMPOSITE, then the FIRM MUST disclose how the FIRM defines a SIGNIFICANT CASH FLOW for that COMPOSITE, and for which period(s). 4.A.28 FIRMS MUST disclose, for a minimum of 12 months, any change to the COMPLIANT PRESENTATION due to a correction of a material error. 4.A.29 FIRMS MUST disclose the 3 year annualized EX-POST STANDARD DEVIATION (using a minimum of monthly periods) for the COMPOSITE and for the BENCHMARK as of the most recent annual period presented. The PERIODICITY of the COMPOSITE MUST be identical to the PERIODICITY of the BENCHMARK when calculating EX-POST STANDARD DEVIATION. Please align all starting points to Please change to: FIRMS MUST disclose for a minimum of 12 month, starting from the date the correction is made, any change to the COMPLIANT PRESENTATION due to a correction of a material error., but please treat consistently throughout GIPS, including provision 5.A.1. Do you agree with the inclusion of a standard deviation disclosure? YES Page 13 of 62

14 4.B Disclosures Recommendations 4.B.1 If a parent company contains multiple defined FIRMS, each FIRM within the parent company SHOULD disclose a list of the other FIRMS contained within the parent company. 4.B.2 FIRMS SHOULD disclose the key assumptions used to value investments. 4.B.3 FIRMS SHOULD disclose the description of the BENCHMARK and FIRMS SHOULD disclose material differences between the BENCHMARK and COMPOSITE strategy. 4.B.3 FIRMS SHOULD disclose the description of the BENCHMARK and FIRMS SHOULD disclose material differences between the BENCHMARK and COMPOSITE strategy. In our opinion this recommendation does not add anything to GIPS. Please make the sentence disclose the description of the BENCHMARK a mandatory provision. We agree with the remainder of the recommendation; this can remain a recommendation. Please make the sentence disclose the description of the BENCHMARK a mandatory provision. We agree with the remainder of the recommendation; this can remain a recommendation. We agree with the deletion of the previously included recommendation. 5. PRESENTATION AND REPORTING 5.A Presentation and Reporting Requirements 5.A.1 The following items MUST be included in each COMPLIANT PRESENTATION: a) At least 5 years of annual performance (or a record for the period since FIRM or COMPOSITE inception if the FIRM or COMPOSITE has been in existence less than 5 years) that meets the REQUIREMENTS of the GIPS standards; after presenting 5 years of annual performance, the FIRM MUST present additional annual performance up to a minimum of 10 years. (For example, after a FIRM presents a minimum 5 years of compliant history, the FIRM MUST add an additional year of performance each year so that after 5 years of claiming compliance, the FIRM presents a minimum 10-year performance record.) b) Annual returns for all years. For COMPOSITES with a COMPOSITE INCEPTION DATE beginning on or after 1 January 2011, when the initial period is less than a full year, FIRMS MUST present returns from the COMPOSITE inception through the initial year-end. Page 14 of 62

15 c) The number of PORTFOLIOS and amount of assets in the COMPOSITE, and either the percentage of the TOTAL FIRM ASSETS represented by the COMPOSITE or the amount of TOTAL FIRM ASSETS at the end of each annual period. If the COMPOSITE contains 5 PORTFOLIOS or less, the number of PORTFOLIOS is not REQUIRED. d) A measure of DISPERSION of individual PORTFOLIO returns for each annual period. If the COMPOSITE contains 5 PORTFOLIOS or less for the full year, a measure of DISPERSION is not REQUIRED. 5.A.2 FIRMS may LINK non-gips-compliant returns to their compliant history so long as the FIRMS meet the disclosure REQUIREMENTS for non-compliant performance and only compliant returns are presented for periods after 1 January A.3 Returns for periods of less than 1 year MUST NOT be annualized. 5.A.4 a) Performance track records of a past firm or affiliation MUST be LINKED to or used to represent the historical record of a new FIRM if, on a COMPOSITEspecific basis: i) Substantially all the investment decision makers are employed by the new FIRM (e.g., research department, portfolio managers, and other relevant staff), ii) iii) The decision-making process remains substantially intact and independent within the new FIRM, and The new FIRM has records that document and support the reported performance. a) Page 15 of 62

16 b) The new FIRM MUST disclose that the performance from the past firm or affiliation are LINKED to the performance record of the new FIRM. c) If a FIRM acquires another firm or affiliation, the FIRM has 1 year to bring any non-compliant assets into compliance. 5.A.5 For periods beginning on or after 1 January 2006 and ending prior to 1 January 2011, if a COMPOSITE includes CARVE-OUTS, the COMPLIANT PRESENTATION MUST include the percentage of the COMPOSITE assets that is composed of CARVE-OUTS. b) c) Please add guidance for the situation that a non-compliant firm acquires a compliant firm. Is it appropriate to discontinue disclosure 5.A.5 for periods after 1 January 2011? YES 5.A.6 The TOTAL RETURN for the BENCHMARK (or BENCHMARKS) that reflects the investment strategy or mandate represented by the COMPOSITE MUST be presented for each period. a) If the FIRM determines no appropriate BENCHMARK for the COMPOSITE exists, the FIRM MUST disclose why no BENCHMARK is presented. b) If the FIRM changes the BENCHMARK, the FIRM MUST disclose the date, nature, and reason(s) for the change. c) If a custom BENCHMARK or combination of multiple BENCHMARKS is used, the FIRM MUST disclose the BENCHMARK creation and re-balancing process. 5.A.7 If a COMPOSITE contains any non-feepaying PORTFOLIOS, the FIRM MUST present, as of the end of each annual period, the percentage of the COMPOSITE assets represented by the non-fee-paying PORTFOLIOS. 5.A.8 For periods beginning on or after 1 January 2011, if a COMPOSITE contains any PROPRIETARY ASSETS, the FIRM MUST present, as of the end of each annual period, the percentage of the COMPOSITE assets represented by the PROPRIETARY ASSETS. a) b) c) Page 16 of 62

17 Do you agree with the requirement to present the percentage of the composite assets composed of proprietary assets? YES 5.B Presentation and Reporting Recommendations 5.B.1 FIRMS SHOULD present GROSS-OF- FEES RETURNS. 5.B.2 FIRMS SHOULD present the following items: a) Cumulative returns for COMPOSITE and BENCHMARKS for all periods, b) Equal-weighted mean and median returns for each COMPOSITE, c) Returns for quarterly and/or monthly time periods, d) Annualized COMPOSITE and BENCHMARK returns for periods greater than 12 months 5.B.3 FIRMS SHOULD present additional relevant COMPOSITE-level risk measures. 5.B.4 After presenting the REQUIRED minimum of 5 years of compliant historical performance, FIRMS SHOULD bring any remaining portion of its historical track record into compliance with the GIPS standards. 5.B.5 FIRMS SHOULD present greater than Please change greater to more than. 10 years of annual performance in the COMPLIANT PRESENTATION. 5.B.6 FIRMS SHOULD update COMPLIANT Please add at least : FIRMS SHOULD update PRESENTATIONS quarterly. COMPLIANT PRESENTATIONS at least 5.B.7 FIRMS SHOULD present the 3 year annualized EX-POST STANDARD DEVIATION (using a minimum of monthly periods) and the corresponding 3 year annualized TOTAL RETURN for each annual period presented for the COMPOSITE and for the BENCHMARK. The PERIODICITY of the COMPOSITE MUST be identical to the PERIODICITY of the BENCHMARK when calculating EX-POST STANDARD DEVIATION. quarterly. Page 17 of 62

18 6. REAL ESTATE Unless otherwise noted, the following REAL ESTATE provisions supplement all the REQUIRED and RECOMMENDED elements of the GIPS standards as outlined in Sections II.0. through Section II.5. REAL ESTATE provisions were first included in the GIPS standards in 2005 and were effective 1 January All COMPLIANT PRESENTATIONS that included REAL ESTATE performance results for periods after 31 December 2005 were REQUIRED to meet all the REQUIREMENTS of the REAL ESTATE provisions of the 2005 version of the GIPS standards. The following REAL ESTATE provisions are effective 1 January Unless otherwise noted, all COMPLIANT PRESENTATIONS that include REAL ESTATE performance results for periods after 31 December 2010 are REQUIRED to meet all the REQUIREMENTS and SHOULD adhere to all the RECOMMENDATIONS of the following REAL ESTATE provisions. If a PORTFOLIO includes a mix of REAL ESTATE and other investments that are not REAL ESTATE, then these REQUIREMENTS and RECOMMENDATIONS MUST apply if the majority of the FAIR VALUE of PORTFOLIO investments are REAL ESTATE. Investment types not considered as REAL ESTATE and, therefore, the FIRM MUST adhere to Sections II.0. through Section II.5., include: Please replace the word REQUIRED with the word MUST in the sentence after 31 December 2005 were REQUIRED Please replace this sentence by: Investment types not considered as REAL ESTATE and therefore, for which the FIRM MUST adhere to Sections II.0. through Section II.5., include: Another question arises by reading this section is how to apply this section e.g. Would this section apply in full, even only 1% of the portfolio is invested in REAL ESTATE? Publicly traded REAL ESTATE securities, including any listed securities issued by public companies, Commercial mortgage-backed securities (CMBS), Private debt investments, including commercial and residential loans where the expected return is solely related to contractual interest rates without any participation in the economic performance of the underlying REAL ESTATE. 6.A Real Estate Input Data Requirements (1.A.3.a, 1.A.3.b, and 1.A.4 do not apply) 6.A.1 8 REAL ESTATE investments MUST be valued at FAIR VALUE at least quarterly in accordance with GIPS Valuation Principles in Appendix D. 8 For periods ending prior to 1 January 2008, REAL ESTATE investments MUST be valued at MARKET VALUE at least once every 12 months. Page 18 of 62

19 6.A.2 REAL ESTATE investments MUST be valued by an independent external PROFESSIONALLY DESIGNATED, CERTIFIED, OR LICENSED COMMERCIAL PROPERTY VALUER/APPRAISER at least once every 36 months. For periods beginning on or after 1 January 2012, REAL ESTATE investments MUST be valued by an independent external PROFESSIONALLY DESIGNATED, CERTIFIED, OR LICENSED COMMERCIAL PROPERTY VALUER/APPRAISER at least once every 12 months. In markets where neither professionally designated nor appropriately sanctioned valuers or appraisers are available and valuers or appraisers from other countries bearing such credentials do not commonly operate, then the FIRM MUST take necessary steps to ensure that only well-qualified independent property valuers or appraisers are used., would prefer if the dates are synchronized (consistently applied within the Standards, e.g. set date to 1 January 2011 Do you agree that real estate investments must be valued by an independent external appraiser every 12 months beginning 1 January 2012? Yes 6.A.3 For periods beginning on or after 1 January 2010, FIRMS MUST value PORTFOLIOS as of the calendar quarter-end or the last business day of the quarter. 6.B Real Estate Input Data Recommendations (1.B.1 and 1.B.4 do not apply) 6.B.1 For periods beginning prior to 1 Disagree. This recommendation should only be January 2012, REAL ESTATE required for maximal one year or else be deleted investments SHOULD be valued by an (Super flues). independent external PROFESSIONALLY DESIGNATED, CERTIFIED, OR LICENSED COMMERCIAL PROPERTY VALUER / APPRAISER at least once every 12 months. 6.A Real Estate Calculation Methodology Requirements (2.A.6 does not apply) 6.A.4 INCOME and CAPITAL RETURNS (component returns) MUST be calculated separately using geometrically LINKED TIME- WEIGHTED RATES OF RETURN. Page 19 of 62

20 6.A.5 TIME-WEIGHTED COMPOSITE returns and component returns MUST be calculated by asset weighting the individual PORTFOLIO returns at least quarterly. The following provision is an additional REQUIREMENT for CLOSED-END REAL ESTATE FUNDS: Do you agree with the additional requirements and recommendations for closed-end real estate funds as defined? YES 6.A.6 9 The annualized since inception INTERNAL RATE OF RETURN (SI- IRR) must be calculated using the period-end valuation of the COMPOSITE as a terminal value. For periods beginning on or after 1 January 2011, SI-IRR MUST be calculated using daily cash flows Yes 6.B Real Estate Calculation Methodology Recommendations The following provision is an additional RECOMMENDATION for CLOSED-END REAL ESTATE FUNDS: 6.B.2 For periods beginning prior to 1 January 2011, the annualized SI-IRR SHOULD be calculated using daily cash flows. 6.A Real Estate Composite Construction Requirements Disagree. This recommendation should only be required for maximal one year or else be deleted (Super flues). The following provision is an additional REQUIREMENT for CLOSED-END REAL ESTATE FUNDS: 6.A.7 Each COMPOSITE MUST be defined Yes by investment strategy and VINTAGE YEAR. These classifications MUST remain consistent throughout the life of the COMPOSITE. 9 When calculating the SI-IRR, the periods beginning prior to 1 January 2011 MUST be calculated at a minimum using quarterly cash flows. Page 20 of 62

21 6.A Real Estate Disclosures Requirements (4.A.10, 4.A.25, and 4.A.29 do not apply) 6.A.8 The following items MUST be disclosed in COMPLIANT PRESENTATIONS for REAL ESTATE COMPOSITES: a. The FIRM S description of discretion. b. The valuation methodologies (e.g., discounted cash flow valuation model, capitalized income approach, sales comparison approach, the valuation of debt payable in determining the value of leveraged REAL ESTATE) and material changes to valuation methodologies. c. For periods beginning on or after 1 January 2012, FIRMS must explain and disclose the impact of material differences between: i) The valuation used in performance reporting and the valuation used in financial reporting. ii) The EXTERNAL VALUATION and the valuation used in performance reporting. d. As a measure of annual dispersion, the high and low TIME-WEIGHTED RATES OF RETURN for the individual PORTFOLIOS in the COMPOSITE. e. The percent of total FAIR VALUE of COMPOSITE assets valued using an EXTERNAL VALUATION to total FAIR VALUE of COMPOSITE assets. f. For periods beginning prior to 1 January 2012, the frequency REAL ESTATE investments are valued by external valuers or appraisers. This requirements appears to conflict with our understanding of the Standards. To our understanding you are either compliant with GIPS or not.,, though would like to synchronize dates within GIPS. Suggest to change the date to 1 January 2011, though would like to synchronize dates within GIPS. Suggest to change the date to 1 January 2011 Page 21 of 62

22 6.A.9 FIRMS MUST disclose the following as applicable: a) Component returns are calculated separately using geometrically LINKED TIME-WEIGHTED RATES OF RETURN and so the sum of income and capital returns may not equal the TOTAL RETURN due to the interaction (compounding) effect. b) Component returns are adjusted such that the sum of income and capital returns is equal to the TOTAL RETURN (allowed only for periods beginning prior to 1 January 2011). 6.A.10 For any TIME-WEIGHTED RATES OF RETURN presented for periods prior to 1 January 2006 that does not comply with the GIPS standards, FIRMS MUST disclose the period of non-compliance. The following provisions are additional REQUIREMENTS for CLOSED-END REAL ESTATE FUNDS: 6.A.11 FIRMS MUST disclose the period of non-compliance when presenting non- GIPS-compliant annualized SI-IRR and MUST meet the disclosure REQUIREMENTS for non-compliant performance. 6.A.12 FIRMS MUST disclose the periods of cash flows used in the SI-IRR calculation if daily cash flows are not used for periods beginning prior to 1 January A.13 FIRMS MUST disclose the VINTAGE YEAR of the COMPOSITE and how the VINTAGE YEAR was defined. 6.A.14 FIRMS MUST disclose the FINAL REALIZATION (LIQUIDATION) DATE of all closed COMPOSITES. 6.B Real Estate Disclosures Recommendations 6.B.3 FIRMS SHOULD disclose the basis of Disagree, this recommendation is inconsistent in accounting for the PORTFOLIOS in the GIPS. GIPS are performance standards and not COMPOSITE (e.g. U.S. GAAP, IFRS or accounting standards. If this recommendation will other basis of accounting). be effective, we suggest to apply it consistently within GIPS (also for private equity etc). Page 22 of 62

23 6.A Real Estate Presentation and Reporting Requirements (5.A.2 does not apply) 6.A.15 FIRM MUST present component returns in addition to TOTAL RETURN. Do you agree that component returns must be disclosed, and that the method described in provision 6.A.9.b will no longer be acceptable for periods beginning after 1 January 2011? YES 6.A.16 FIRMS may LINK non-gips-compliant TIME-WEIGHTED RATES OF RETURN to compliant history so long as the FIRMS meet the disclosure REQUIREMENTS for non-compliant performance and only compliant returns are presented for periods after 1 January The following provisions are additional REQUIREMENTS for CLOSED-END REAL ESTATE FUNDS: 6.A.17 FIRMS MUST present NET-OF-FEES annualized SI-IRR of the COMPOSITE for each year since the COMPOSITE inception and FIRMS MUST present at least 5 years of performance (or a record for the period since FIRM or COMPOSITE inception if the FIRM or COMPOSITE has been in existence less than 5 years) that meets the REQUIREMENTS of the GIPS standards. When the initial period is less than a full year, FIRMS MUST present NET-OF-FEES annualized SI-IRR from COMPOSITE inception through the initial year end. 6.A.18 If GROSS-OF-FEES annualized SI- IRR is presented, FIRMS MUST present GROSS-OF-FEES annualized SI-IRR of the COMPOSITE for each year since COMPOSITE inception and FIRMS MUST present at least 5 years of performance (or a record for the period since FIRM or COMPOSITE inception if the FIRM or COMPOSITE has been in existence less than 5 years) that meets the REQUIREMENTS of the GIPS standards. When the initial period is less than a full year and GROSS-OF- FEES annualized SI-IRR is presented, FIRMS MUST present GROSS-OF-FEES annualized SI-IRR from COMPOSITE inception through the initial year end., please provide further guidance (details) on the wording through the initial year end, please provide further guidance (details) on the wording through the initial year end Page 23 of 62

24 6.A.19 FIRMS MUST present, as of each period end: a. Total COMPOSITE since inception COMMITTED CAPITAL b. Total COMPOSITE since inception PAID-IN CAPITAL (cumulative DRAWDOWN) c. Total COMPOSITE since inception cumulative INVESTED CAPITAL d. Total COMPOSITE since inception cumulative DISTRIBUTIONS 6.A.20 FIRMS MUST present, as of each period end: a. TOTAL VALUE to PAID-IN CAPITAL (INVESTMENT MULTIPLE or TVPI) b. Cumulative DISTRIBUTIONS to PAID-IN CAPITAL (REALIZATION MULTIPLE or DPI) c. PAID-IN CAPITAL to COMMITTED CAPITAL (PIC MULTIPLE) d. RESIDUAL VALUE TO PAID-IN CAPITAL (RVPI) 6.B Real Estate Presentation and Reporting Recommendations (5.B.1 and 5.B.7 do not apply) 6.B.4 FIRMS SHOULD present GROSS-OF- FEES TOTAL RETURN and NET-OF- FEES TOTAL RETURN. 6.B.5 When available, the component returns of the appropriate REAL ESTATE BENCHMARK SHOULD be presented., please include the recommendation to disclose the method of the components returns used. The following provision is an additional RECOMMENDATION for CLOSED-END REAL ESTATE FUNDS: 6.B.6 FIRMS SHOULD present GROSS-OF- FEES annualized SI-IRR for each year since COMPOSITE inception. Page 24 of 62

25 7. PRIVATE EQUITY Unless otherwise noted, the following PRIVATE EQUITY provisions supplement all the REQUIRED and RECOMMENDED elements of the GIPS standards as outlined in Sections II.0. through Section II.5., though a question arises by reading this section is how to apply this section e.g. Would this section apply in full, even only 1% of the portfolio is invested in PRIVATE EQUITY? PRIVATE EQUITY provisions were first included in the GIPS standards in 2005 and were effective 1 January All COMPLIANT PRESENTATIONS that included PRIVATE EQUITY performance results for periods after 31 December 2005 were REQUIRED to meet all the REQUIREMENTS of the PRIVATE EQUITY provisions of the 2005 version of the GIPS standards. The following PRIVATE EQUITY provisions are effective 1 January Unless otherwise noted, all COMPLIANT PRESENTATIONS that include PRIVATE EQUITY performance results for periods after 31 December 2010 are REQUIRED to meet all the REQUIREMENTS and SHOULD adhere to all the RECOMMENDATIONS of the following PRIVATE EQUITY provisions. The following are provisions that apply to the calculation and presentation of PRIVATE EQUITY investments other than PRIVATE EQUITY OPEN-END and EVERGREEN FUNDS (which MUST follow the main GIPS provisions), and CLOSED-END REAL ESTATE FUNDS (which MUST follow Section II.6). 7.A Private Equity Input Data Requirements (1.A.3 and 1.A.4 do not apply) 7.A.1 10 For periods beginning on or after 1 January 2011, PRIVATE EQUITY investments MUST be valued at FAIR VALUE at least annually in accordance with the GIPS Valuation Principles in Appendix D. 7.A.2. For periods beginning on or after 1 January 2010, FIRMS MUST value PORTFOLIOS as of the calendar yearend or the last business day of the year. 7.B Private Equity Input Data Recommendations (1.B.4 does not apply) 7.B.1 PRIVATE EQUITY investments SHOULD be valued at FAIR VALUE quarterly in accordance with the GIPS Valuation Principles in Appendix D. Disagree, Please replace the word quarter by quarter-end or last business day 7.A Private Equity Calculation Methodology Requirements (2.A.2, 2.A.3, and 2.A.6 do not apply) 7.A.3 FIRMS MUST calculate the annualized since-inception INTERNAL RATE OF RETURN (SI-IRR). 10 For periods ending prior to 1 January 2011, PRIVATE EQUITY investments MUST be valued according to the GIPS Private Equity Valuation Principles. The GIPS Private Equity Valuation Principles can be found in Appendix D of the 2005 version of the GIPS standards on the GIPS website ( Page 25 of 62

26 7.A.4 11 For periods beginning on or after 1 January 2011, the annualized SI-IRR MUST be calculated using daily cash flows and the period-end valuation of the COMPOSITE as a terminal value. Stock DISTRIBUTIONS MUST be included as cash flows and MUST be valued at the time of DISTRIBUTION. 7.A.5 NET-OF-FEES RETURNS MUST be net of actual INVESTMENT MANAGEMENT FEES (including CARRIED INTEREST) and TRANSACTION EXPENSES. 7.A.6 All returns MUST be net of all underlying partnership and/or fund fees and CARRIED INTEREST and NET-OF-FEES RETURNS MUST, in addition, be net of all actual INVESTMENT MANAGEMENT FEES, expenses, and CARRIED INTEREST. Disagree, this requirement is not inline with 4.A.16B, though please provide further explanation on the word actual 7.B Private Equity Calculation Methodology Recommendations 7.B.2 For periods beginning prior to 1 January 2011, the annualized SI-IRR SHOULD be calculated using daily cash flows. 7.A. Private Equity Composite Construction Requirements (3.A.10 does not apply) 7.A.7 All PRIVATE EQUITY investments, excluding funds of funds, MUST be included in a COMPOSITE defined by investment strategy and VINTAGE YEAR. These classifications MUST remain consistent throughout the life of the COMPOSITE. 7.A.8 Partnership/fund investment strategies and DIRECT INVESTMENT strategies MUST be included in separate COMPOSITES. 7.A.9 For funds of funds, all discretionary investments MUST be included in at least one COMPOSITE defined by investment strategy and/or VINTAGE YEAR. Disagree, strongly object to exclude fund of fund. Please provide further explanation why this is excluded! Disagree, please see our comments on 7.A.7 7.B. Private Equity Composite Construction Recommendations (3.B.1 does not apply) 11 When calculating the SI-IRR, periods beginning prior to 1 January 2011 MUST be calculated using either daily or monthly cash flows. Page 26 of 62

27 7.A. Private Equity Disclosures Requirements (4.A.10, 4.A.25, 4.A.26, 4.A.27, and 4.A.29 do not apply) 7.A.10 FIRMS MUST disclose the VINTAGE YEAR of the COMPOSITE and how the VINTAGE YEAR is defined. 7.A.11 FIRMS MUST disclose the FINAL LIQUIDATION DATE of all liquidated COMPOSITES. 7.A.12 FIRMS MUST disclose the unrealized appreciation/depreciation of the COM- POSITE for the most recent period. 7.A.13 FIRMS MUST disclose the valuation methodologies used to value PRIVATE EQUITY investments. If any material change in valuation methodologies occurred, the change MUST be disclosed. 7.A.14 If the COMPLIANT PRESENTATION complies with valuation guidelines in addition to the GIPS Valuation Principles, FIRMS MUST disclose which guidelines have been used. 7.A.15 FIRMS MUST disclose the calculation methodology used for the BENCHMARK. If FIRMS present the PUBLIC MARKET EQUIVALENT of a COMPOSITE as a benchmark, FIRMS MUST disclose the index used. 7.A.16 FIRMS MUST disclose if a valuation basis other than FAIR VALUE was used for periods beginning prior to 1 January A.17 FIRMS MUST explain and disclose the impact of material differences between the valuation used in performance reporting and the valuation used in financial reporting at period end. 7.A.18 FIRMS MUST disclose the frequency of cash flows used in the SI-IRR calculation if daily cash flows are not used for periods beginning prior to 1 January A.19 FIRMS MUST disclose any period of noncompliance and MUST meet the disclosure REQUIREMENTS for noncompliant performance., please do provide more guidance on the word material,, please provide further explanation on the word material This requirements (or section of GIPS) is not inline with the other sections. If the requirement remains in GIPS 2010, we suggest to apply it consistently within GIPS.. Page 27 of 62

28 7.A Private Equity Presentation and Reporting Requirements (5.A.1.a, 5.A.1.b, 5.A.1.d, and 5.A.2 do not apply) 7.A.20 FIRMS MUST present both the NET-OF- FEES and GROSS-OF-FEES annualized SI-IRR of the COMPOSITE for each year since COMPOSITE inception and FIRMS MUST present at least 5 years of performance (or a record for the period since FIRM or COMPOSITE inception if the FIRM or COMPOSITE has been in existence less than 5 years) that meets the REQUIREMENTS of the GIPS standards. When the initial period is less than a full year, FIRMS MUST present the NET-OF-FEES and GROSS-OF-FEES annualized SI-IRR from the COMPOSITE inception through the initial year end. 7.A.21 For periods beginning on or after 1 January 2011, for funds of funds, if the COMPOSITE is defined by investment strategy only, FIRMS MUST also present the GROSS-OF-FEES and/or NET-OF- FEES annualized SI-IRR of the underlying funds by VINTAGE YEAR as of the most recent year end. 7.A FIRMS MUST present as of each period end: a) Total COMPOSITE since inception PAID-IN CAPITAL (cumulative DRAWDOWN), b) Total COMPOSITE since inception DISTRIBUTIONS 7.A.23 For periods beginning on or after 1 January 2011, FIRMS MUST present as of each period end a) Total COMPOSITE since inception COMMITTED CAPITAL b) Total COMPOSITE since inception AMOUNT REALIZED 7.A.24 FIRMS MUST present as of each period end: a) TOTAL VALUE to PAID-IN CAPITAL (INVESTMENT MULTIPLE or TVPI), b) Cumulative DISTRIBUTIONS to PAID-IN CAPITAL (REALIZATION MULTIPLE or DPI) c) PAID-IN CAPITAL to COMMITTED CAPITAL (PIC MULTIPLE) d) RESIDUAL VALUE to PAID-IN CAPITAL (RVPI) Disagree, refer to comments 7.A For periods beginning prior to 1 January 2011, FIRMS MUST present the total current INVESTED CAPITAL for each period presented. Page 28 of 62