GIPS Guidance Statement on Error Correction

Transcription

1 GIPS Guidance Statement on Error Correction Susanne Klemm, Ernst & Young 27 November, 2008

2 Content Effective date Scope of the guidance Possible sources of errors Basis for this guidance Define prospective client How to deal with errors Error correction policies and procedures Definition of materiality and possible options Case example incorrect composite return Asset manager s examples Possible questions of the verifier Concluding remarks

3 Effective Date Public comment period: October February 2005 Adopted 18 June 2008 Effective date:1 January 2010 Firms must establish error correction policies and procedures by the effective date Firms must follow their procedures for any error in a compliant presentation identified after 31 December Firms are strongly encouraged but not required to adopt this guidance prior to the effective date No retroactive application required

4 Scope of this guidance An error is defined as any component of a compliant presentation that is missing or inaccurate. Adjustments to prior period returns or presentations. Errors can be quantitative and/or qualitative. The Guidance Statement on Error correction addresses errors related to GIPS compliant presentations, but not the errors discovered in advertisements prepared following the GIPS Advertising Guidelines.

5 Possible sources of errors Errors can result from incorrect, incomplete or missing Composite or benchmark returns Composite or firm assets Number of portfolios in a composite Measure of dispersion Disclosure Etc. Errors can be caused by Input data errors Prior period adjustments Incorrect timing of inclusion and/or exclusion of portfolios to composites Inadequate creation or implementation of policies and procedures Etc.

6 Basis for this guidance statement The fundamental principle of the GIPS is fair representation and full disclosure. Firms must, therefore, avoid presenting misleading information. 0.A.11 requires firms to make every reasonable effort to provide a compliant presentation to all prospective clients. 0.A.6 states that firms must document, in writing, their policies and procedures. A firm must establish error correction policies and procedures.

7 Define prospective client Every reasonable effort must be made to provide the corrected presentation to all prospective clients and other parties that received the erroneous presentation, including consultants and verifiers. (p.5, GS on Error Correction) Prospective client: It is up to the firm to determine how it defines a prospective client. (p. 73 GIPS Handbook)

8 Define prospective client - continued Initial contact visit phone/fax no Interested party not qualified as a prospective client Becomes actual client yes yes List of clients Prospective client Reasonable effort GIPS report List of composites Opening of account no List of potential clients (and other parties) who have received GIPS reports Prospect becomes lost opportunity client List of past prospective clients

9 Define prospective client - continued Initial contact visit phone/fax no Interested party not qualified as a prospective client Becomes actual client yes yes List of clients Prospective client Reasonable effort GIPS report List of composites Opening of account no List of potential clients (and other parties) who have received GIPS reports Make every reasonable effort to provide corrected presentations Prospect becomes lost opportunity client List of past prospective clients

10 How to deal with errors: requirements Requirements Error correction policies and procedures must be established and then implemented consistently Materiality must be defined in the error correction policies When an error occurs, it is important that the firm assesses the impact and determines whether the corrective action will meet the guiding principles. Requirements if an error is material The error must be corrected and disclosed Disclosure of the change must be shown for a min. of 12 months All existing clients that received the erroneous presentation must receive a corrected version Every reasonable effort must be made to provide the corrected presentation to all prospective clients and other parties that received the erroneous presentation

11 How to deal with errors: recommendations Recommendations for error correction entail policies and procedures that should be unambiguous and include specific steps to discover and correct errors. include how the corrected presentation will be distributed to all applicable parties. include procedures for documenting the error and actions taken.

12 Error correction policies and procedures The firm should identify the principal parties within the organization that are integral to GIPS compliance and ensure that these parties communicate with each other. Errors must be identified, assessed, documented, communicated, escalated. Within the firm a framework should be in place by which material errors in presentations can be detected and corrected. Given the materiality and nature of the error, various error scenarios can be set up.

13 Error correction policies and procedures continued Factors to consider When determining error correction policies and procedures, a firm should regard the materiality of the error (in absolute or relative terms) whether the error is material relative to the benchmark whether returns were overstated or understated the significance of the missing or incorrect disclosures whether the error affects returns over time the period(s) affected by the error whether the policies will be applied on a firm-wide or on a composite-specific basis whether erroneous presentations have been provided to prospective clients, existing clients or other parties whether the firm is legally obligated to correct and/or disclose the corrections

14 Definition of materiality A key determinant of materiality is whether an error might affect a prospective client s investment decision and appropriate action is necessary to resolve the issue. Size and impact of the error may vary for Asset classes (setting different thresholds) Reporting periods Time periods

15 Definition of materiality and possible options Option 1 Option 2 Option 3 Option 4 No action Immaterial No change of data No disclosure of error Correction but no disclosure Not material Correction of presentation No disclosure of error No distribution Correction with disclosure Not material Correction of presentation Disclosure of error No distribution Correction with disclosure and reasonable effort to distribute Material Correction of presentation Disclosure of error Reasonable effort to provide corrected presentation to all prospective clients and other parties Min. 12 months

16 Case example incorrect composite return 1. Identify the error 2. Recalculate the returns and quantify the error 3. Is the error material? 4. Decide which action to take Option 1 immaterial Option 2 not material Option 3 not material Option 4 material 5. Document the original return, the corrected value and the action taken

17 Asset manager s examples Funds Accounting Team Asset Management Team Sales & Marketing Team Performance Team Providing information about an error Performance Team Processing determining of the period affected by error and recalculation Performance Team Definition of materiality Material error Result comparison Decision about error s materiality Performance Team Not material error Republishing Restatement Is it possible to reach presentation receiver? yes Contact and information about correction Sales Team (B2B) no Publishing of corrected presentation Correction in the next presentation without publishing information about error Marketing Team

18 Possible questions of the verifier Has the firm defined and recorded an error correction policy and procedures? Which procedures are in place to identify errors? What levels of materiality have been defined? Definition of prospective client The asset manager should provide a list of parties that have received GIPS compliant reports The asset manager should provide a list of parties that have received corrected reports

19 Possible questions of the verifier continued Have there been any errors recorded in the period to be verified and if yes, what kind of errors have been identified? Are the errors detected during the verification considered material according to the asset manager s definition of materiality? What steps have been taken to correct the erroneous report, document the error and distribute the corrected presentation to the affected parties? Have material errors been disclosed for at least 12 months?

20 Concluding remarks Fair representation and full disclosure Establish unambiguous policies and procedures for the correction of errors Define when an error is deemed material or not Do not forget policies to detect errors Establish communication processes between all involved parties List composite report addressees Start to think about your policies, try out materiality levels suited to your products and services It is worth it!

21 Your questions?

22 Susanne Klemm Ernst & Young Investment Performance Services Belpstrasse 23 P.O. Box 3001 Bern Phone Mobile

23 Practical Issues: GIPS Setup at Julius Bär GIPS Aperitif Zurich, 27 November 2008 Daniel Koller Head Investment Risk Bank Julius Bär

24 GIPS setup at Julius Bär Structure Julius Baer Organisation Investment Risk department GIPS Implementation > within Private Banking > within Asset Management Seite TitelGIPS Aperitif Nov-2008

25 Julius Baer Group Structure and AuM Julius Bär By brands and businesses Julius Baer { 364bn 63bn 17% Bank Julius Baer 222bn Asset Management 142bn 116bn 32% 185bn 51% Private Banking Investment Products GAM Artio 148bn 74bn 68bn 74bn Private clients Private clients via third-party distributors 2 GIPS Firms Institutional clients All figures in CHF as of 30 June 2008 Effective 15 June 2008 Julius Baer Americas Inc. is Artio Global Investors Inc. All figures in CHF as of 30 June 2008 Seite TitelGIPS Aperitif Nov-2008

26 Julius Baer Group: Key Figures All figures in CHF Seite TitelGIPS Aperitif Nov-2008

27 Bank Julius Baer - Offices Hamburg London Guernsey Zurich Basel Berne Geneva Lausanne Lugano Lucerne Paris Switzerland Sion Crans-Mt. Zug Verbier St. Gallen St. Moritz Stuttgart Monaco Düsseldorf Milan Frankfurt Istanbul Vienna Moscow Mexico City Bahamas Cayman Islands Cairo Dubai Abu Dhabi Hong Kong Bogotá Singapore Jakarta Montevideo Buenos Aires Booking Centers Existing locations Locations opened / planned 2008 Seite TitelGIPS Aperitif Nov-2008

28 GIPS Organisation at Bank Julius Bär CEO BJB CRO BJB Credit Risk Banking Relationship Mgt Market Risk, ALM & Product Control Business Risk & Operational Risk Investment Risk Independent organisational unit responsible both for PB and Institutional Business Investment/guideline controlling (Mig21, Triple-A) Quant services (Wilshire factor attribution, Risk Metrics VaR) GIPS compliance & reporting (Statpro) Investment Controlling PB Investment Controlling Funds & Institutional Mandates Performance Analytics (Quants) Performance & GIPS Private Banking Performance & GIPS Funds & institutional mandates Seite TitelGIPS Aperitif Nov-2008

29 Investment Controlling Funds/Institutionals MIG21 Example Seite TitelGIPS Aperitif Nov-2008

30 Investment Analytics: Example (Equity Fund) Portfolio: Europe Leading Stock Fund Benchmark: Dow Jones STOXX 50 Date: Analysis date Value (Mio.): Portfolio value (E/DM) and currency Key Figures ex-ante volatility start ( ) date ex-ante volatility ( ) end date return ( return over period ) risk-adjusted return absolute relative %var absolute relative %var absolute relative absolute relative Factor % % Currency % % Region % % Country % % Industry % % Fundamental % % Specific Risk / Selection % % Risk-free return Total (daily holdings-based) ex-ante tracking errors at beginning and end of period ex-post performance attribution and risk-adjusted performance Seite TitelGIPS Aperitif Nov-2008

31 Investment Analytics: Example (Equity Fund) cont. Industry: rel. volatility % (start) outperformance % rel. volatility % (end) rel. weight % (start) rel. weight % (end) Diversified Financials (EU) Insurance (EU) Capital Goods (EU) Software & Services (EU) Tech Hardware & Equipment (EU) Energy (EU) Underperformance due to underweight in energy, overweight in technology Fundamental: rel. volatility % (start) outperformance % rel. volatility % (end) rel. z-score (start) rel. z-score (end) Log Market Cap (EU) Volatility (EU) Momentum (EU) Book/Price (EU) E/P Ratio (EU) Overcompensated by successful style factor positioning (size, volatility) Seite TitelGIPS Aperitif Nov-2008

32 Investment Risk Performance & GIPS Performance Team Funds & Institutional Mandates Performance Calculation of institutional mandates on PM System (Simcorp Dimension) Support quarterly client reporting Funds performance: data administration on database Fundus PM + Marketing support in all performance issues Maintain GIPS compliant data on Statpro, produce quarterly GIPS booklets + support yearly verification process Performance Team Private Banking Performance Calculation of PB mandates on Triple-A Measure performance of investment process (SAA, TAA, Modelportfolios) Produce performance contribution reports and active participation in different committees Maintain GIPS compliant data on Statpro, produce quarterly GIPS reports, support yearly verification process Seite TitelGIPS Aperitif Nov-2008

33 GIPS in Private Banking (1) Base information GIPS compliant since Definition of the firm: All discretionary PB mandates managed in Switzerland Number of compliant composites: 102 (325 in total; rest = restricted, special, transition, etc.) System = Statpro (new web-based version) External verifier: Ernst & Young, periodicity = yearly Implementation rationale Guarantee for potential and existing clients that the Portfolio Management is based on a structured and well-controlled Investment Process Guarantee that performance information is complete and presented in a true and fair way More transparency for performance comparison on national and international level GIPS-performance is basis for internal analysis of Investment Process, monthly presented to management (Product Review Committee) Seite TitelGIPS Aperitif Nov-2008

34 GIPS in Private Banking (2) Specific Intranet section containing (amongst others) Disclosures Official GIPS/SPPS Report Composite Performance Firm Name Julius Baer Private Banking Switzerland Composite Discretionary Mandates CHF Balanced Reporting Currency CHF Inception Date 01 Jan 2002 Series Type Asset Weighted Gross Return Indexed Return Since Inception Composite Benchmark Period Difference Return % Return % Jan 02 - Dec Period Composite Return % Benchmark Return % Difference Composite Dispersion No. of A/Cs Market Value (m) End of Period % of Firm's Assets Total Firm Assets (m) In ce p Ja n 02 F e b 0 2 M ar 0 2 Ap r 0 2 M a y 0 2 Ju n 02 Ju l 0 2 A u g 02 Composite Benchmark 1 S e p 02 O c t 0 2 N o v 0 2 D e c '475 Quarterly update Quarterly Returns (last 2 years or since inception) -3-4 Composite Benchmark Annual Average Return Since Inception Julius Baer Private Banking Switzerland has prepared and presented this report in compliance with the Swiss Performance Q 1 02 Q Q 3 02 Q 4 02 Presentation Standards (SPPS), the Swiss Version of the Global Investment Performance Standards (GIPS). For further benchmark and general information please refer to the disclosure booklet. Composite Benchmark 1 Report Generated on 28 Feb Page 1 of 1 Seite TitelGIPS Aperitif Nov-2008

35 GIPS in Private Banking (3) Clients Focus of client on Performance of individual mandate (based on Host Performance Modified Dietz) Benchmark often only a supplementary information (often not understood by PB client) Many individual restrictions (needs criteria for inclusion into composites) Sometimes client want to participate in investment decisions Absolute return orientation versus relative return mandates Portfolio Due to restrictions often only limited value when allocating to composite Individual review of positions and actions taken Controlling Enhanced governance due to more disciplined implementation Increased transparency Marketing Ethical standards merely of theoretical value clients don t know them. GIPS report or disclosure hardly ever demanded! Seite TitelGIPS Aperitif Nov-2008

36 Conclusion GIPS PB Topic + - Commitment to ethical standards Misrepresentation or ambiguity when presenting performance clearly reduced Well controlled Investment Process -basis for proper calculation of product performance -transparency in the contribution of each step within the investment process on a agreed upon methodology -useful additional measures like dispersion on composite level Complexity Additional requirements driving cost & complexity (e.g. error correction statement, definition of prospective client ) Marketing use Family office and large clients Regular Private Banking clients are hardly aware of GIPS as a brand Seite TitelGIPS Aperitif Nov-2008

37 Critical comment about GIPS in PB cumulated value added re. transparency 100% de facto market relevance of GIPS in institutional business de facto market relevance of GIPS in PB business 0% 1993 AIMR PPS 1997 SPPS 1999 GIPS 2002 SPPS as CV GIPS 2006 Gold GIPS Time, # requirements GIPS as an industry standard did not yet arrive in PB different sales process in PB as an important factor needed in PB: GIPS as a must have brand like ISO or TÜF the market must ask for GIPS not the client advisor! Seite TitelGIPS Aperitif Nov-2008

38 GIPS in Investment Products (1) Base information GIPS compliant since Definition of the firm: All funds and institutional mandates managed by Julius Baer Investment Products in Switzerland (former Asset Management Europe) Number of compliant composites: 119 (others: non discr. ptf., transition ptf, ptf < 5 mio SFr, etc.) Allocation of portfolios to composites: automated process but can be manually overruled System: Statpro Composites External verifier: PwC, periodicity = yearly Implementation rationale De facto a must for institutional business Important control tool for portfolio administration ( Laufzettel : start and end of process is with GIPS officer) for performance analytic purposes on composite level: long term track record, dispersion measures (as a supplement to analytics on individual portfolio level performed with Wilshire Atlas, Axiom, Spectrum and Risk Metrics) Seite TitelGIPS Aperitif Nov-2008

39 GIPS in Investment Products (2) Reporting Quarterly GIPS booklet, containing all definitions, disclosures and composite reports (170 p.) Monthly updates for individual composites on ad hoc basis Special consideration Use of group composites (aggregation of composites with similar asset allocation) Small portfolios (< 5 mio SFr) Error correction Seite TitelGIPS Aperitif Nov-2008

40 Questions arising from centralisation of GIPS functions PB and Investment Products in one organisational unit Combine the two GIPS firms? Use only one system? Align report formats? Cost implications? Seite TitelGIPS Aperitif Nov-2008

41 Thank you very much for your attention Contact: Daniel Koller CFA, FRM Head Investment Risk Bank Julius Baer +41 (0)

42 GIPS 2010 Revision: Status and Outlook 27 November 2008 Zurich Dimitri Senik PricewaterhouseCoopers

43 Purpose of the GIPS 2010 revision Review of the current GIPS recommendations as candidates for new requirements Review of the proposed implementation dates for the future requirements Clean-up the current GIPS, e.g. remove outdated provisions, etc. Review definitions and glossary Research the current needs of the users of the GIPS standards Develop new provisions where necessary and incorporate them in GIPS 2010 Page 2 11/02/2009 "GIPS 2010"

44 Time schedule for GIPS Beginning of End of Review of the current GIPS Draft of GIPS 2010 GIPS 2010 public comment period (at least 6 months) Finalisation of GIPS 2010 and approval by GIPS EC and by CFA Institute's board GIPS 2010 are published GIPS 2010 become effective A lot in the draft of GIPS 2010 may change as a result of the public comment! Page 3 11/02/2009 "GIPS 2010"

45 Who is working on GIPS 2010 revision Interpretations Subcommittee (majority of work) Interpretations Subcommittee CFAI Director Practitioners / Verifiers Subcommittee Investors / Consultants Subcommittee Further subcommittees and dedicated expert groups (special topics, e.g. Private Equity) Executive Committee (final decisions and approval) Investment Management Subcommittee Positions above the line appointed by CFA Institute Positions below the line appointed by Country Sponsors RIPS Americas GIPS EXECUTIVE COMMITTEE Promotions/ Awareness Subcommittee RIPS EMEA Council Chair RIPS Asia Pacific GIPS COUNCIL Page 4 11/02/2009 "GIPS 2010"

46 GIPS 2010: status / progress Interpretations Subcommittee has reviewed all existing GIPS provisions and guidance and submitted a first draft of the GIPS sections 0 5 to the Executive Committee in September 2008 Verification Subcommittee has reviewed Section III of GIPS The Real Estate and Private Equity Provisions and Guidance are currently being reviewed by the dedicated specialist working groups Investment Manager Subcommittee and the Investor/Consultant Subcommittee are working on a possible extension of GIPS to reporting to existing clients Risk Working Group has developed a first proposal how to address investment risk measurement and presentation within GIPS Alternative Investments Working Group has produced a first draft of the GIPS Guidance for Alternative Investments Page 5 11/02/2009 "GIPS 2010"

47 Status of GIPS recommendations GIPS recommendations should now be viewed as best practice and not as future requirements (for example, accrual accounting for dividends) Page 6 11/02/2009 "GIPS 2010"

48 Future "effective dates (from ) Portfolios must be valued at all large external cash flows Portfolios must be valued at calendar month-end or last business day of the month Composite returns must be calculated at least on a monthly basis Carve-outs must be managed separately with their own cash balances GIPS Executive Committee has confirmed that all above provisions will become effective from Page 7 11/02/2009 "GIPS 2010"

49 True TWR as a future requirement From firms must revalue portfolios at month end and on the date of all large cash flows Definition of a large cash flow can be established on a composite-specific basis Likely requirement in GIPS 2010 to apply the large cash flow policy consistently and the prohibition to revalue for cash flows that don t meet the level of a large cash flow for the composite Possibly a recommendation to revalue portfolios on the date of all external cash flows Page 8 11/02/2009 "GIPS 2010"

50 Type of assets to include in the GIPS firm Current GIPS provision: Assets to which the Standards cannot be applied are not to be considered by firms when claiming compliance and are not to be included in total firm assets. Such assets include investment vehicles that are based on cost or book values rather than market values. Historically, certain assets were excluded from GIPS compliance, such as works of art and other assets where there is no market value GIPS 2010: If the assets are managed as part of an investment strategy, they must be included in the GIPS firm, regardless of the ability to value Page 9 11/02/2009 "GIPS 2010"

51 Non-fee paying portfolios Current GIPS: Non-fee-paying discretionary portfolios do not have to be included in the composites If non-fee-paying portfolios are managed like fee-paying portfolios, why should they be allowed to be excluded from composites based simply on fee-paying status? GIPS 2010: The distinction between fee-paying and nonfee-paying portfolios should be removed when considering composite construction The disclosure of the percentage of the composite composed of non-fee paying portfolios as of each annual period end will likely remain Page 10 11/02/2009 "GIPS 2010"

52 Market value vs. Fair value The definition of market value will be expanded to include the notion of fair value for all assets GIPS Interpretations Subcommittee and the Private Equity Working Group are developing a fair value framework within GIPS for all asset classes (to be accomodated as Appendix D of GIPS) Fair value basis consistent with international financial reporting principles (US GAAP and IFRS) Possible recommendation to disclose key assumptions and principles used to value investments Page 11 11/02/2009 "GIPS 2010"

53 Fair value how accurate? Page 12 11/02/2009 "GIPS 2010"

54 Risk measures GIPS have been criticised for the focus mainly on investment returns and less on investment risks Risk Working Group has been created to address the aspects of presentation of investment risk Qualitative risk descriptions / disclosures are expected One quantitative risk measure will likely be required (current proposal: annualised ex-post standard deviation of the composite and the corresponding benchmark for the most recent 3 year period) Page 13 11/02/2009 "GIPS 2010"

55 MWR returns in GIPS GIPS currently require TWR for all asset classes except Private Equity GIPS 2010: May recommend MWR (e.g. IRR) in all cases when managers are responsible for the timing and size of capital flows Additional work is being carried out to ascertain how this concept may be implemented within GIPS and if an IRR is the most appropriate calculation TWR will still be required as a point of comparison between firms Page 14 11/02/2009 "GIPS 2010"

56 Verification GIPS Executive Committee has decided not to pursue mandatory verification for firms claiming compliance with GIPS Instead, GIPS 2010 will prescribe a revised compliance statement that will include an explicite statement regarding if the firm has or has not been verified In Switzerland the majority of the GIPS compliant firms undergo the verification voluntarily Page 15 11/02/2009 "GIPS 2010"

57 Prospective vs. existing client Definition of the prospective client : Investment Manager Subcommittee is in the process of creating a guidance Presentations to existing clients: GIPS 2010 are expected to recommend providing a relevant GIPS compliant presentation to the existing clients on an annual basis (issue: transparency vs. practicability) Page 16 11/02/2009 "GIPS 2010"

58 Take a break Page 17 11/02/2009 "GIPS 2010"

59 Some further changes in GIPS 2010 (1) Disclosure of the composite characteristics: The current disclosure of the composite description to include enough information to understand all key characteristics of the composite strategy, including risks Longevity of disclosures: Additional guidance for how long certain disclosures must be included in compliant presentations Proprietary portfolios: Expected requirement to disclose the percentage of the composite composed of proprietary portfolios Page 18 11/02/2009 "GIPS 2010"

60 Some further changes in GIPS 2010 (2) Length of the presented track-record: Expected to include a recommendation to present >10 years of composite history Obsolete and outdated provisions: Some provisions of the current GIPS, especially in the area of presentation and disclosures, will be either simplified or removed Page 19 11/02/2009 "GIPS 2010"

61 Further details are available from Page 20 11/02/2009 "GIPS 2010"

62 Your action required... Take an active part in the GIPS 2010 public comment process! Page 21 11/02/2009 "GIPS 2010"

63 Questions? Dimitri Senik, CFA PricewaterhouseCoopers Zurich Tel.: dimitri.senik@ch.pwc.com Internet: Page 22 11/02/2009 "GIPS 2010"