Performance Composite Report Template (GIPS-aligned)
Firm and composite definition, benchmark, annual returns with 3-yr SD and dispersion, fees, TWR/MWR method, valuation, errors, verification, checklist
Mode d'emploi: Use it when a firm prepares or refreshes the annual composite report for prospective clients and consultants. Fill the firm definition, composite membership rules and the annual returns table first, and insert the compliance statement and trademark notice from the official standards. The main pitfall is a report that implies compliance or paraphrases required wording instead of taking it from the GIPS standards.
Aperçu
Performance Composite Report: [Composite name]
Annual performance report for one composite (the set of discretionary portfolios that follow the same strategy and are reported together as one track record), prepared by a firm that claims compliance with, or reports in the format of, the GIPS® standards (2020 edition for Firms, the current edition as of 2026-10). It covers the firm definition, the composite and benchmark, the annual return table with risk and dispersion statistics, the fee schedule, the calculation methodology (time-weighted and money-weighted returns), valuation, significant events, verification and a disclosure checklist written in our own words. The worked example is the fictional adviser Kestrel Bay Capital. Replace every
[bracketed]value and every row marked Example. This template does not make a firm compliant: compliance is claimed firm-wide, and the required statements and disclosures must be taken from the official GIPS standards. This is a document format, not investment, legal or accounting advice. Obtain the standard or law for the normative text.
Document control
| Field | Value |
|---|---|
| Document ID | [PCR-KBC-GQE-2025] |
| Version | [1.0] |
| Status | [Draft / Approved / Superseded / Restated] |
| Owner | [@head-of-performance] |
| Approvers/reviewers | [@chief-investment-officer], [@chief-compliance-officer], [@performance-oversight-committee] |
| Last updated | YYYY-MM-DD |
| Classification | [Public once approved / Internal draft] |
| Firm | [Firm name as defined in section 1] |
| Composite | [Composite name and code] |
| Reporting currency | [USD / EUR / other] |
| Period covered | [YYYY-MM-DD] to [YYYY-MM-DD] (annual periods) |
| Standard referenced | GIPS standards, 2020 edition for Firms; check for later editions and guidance statements |
| Verification status | [Verified through YYYY-MM-DD by [verifier] / Not verified] |
| Related documents | [Composite list and descriptions], [GIPS policies and procedures], [Valuation policy], [Attribution report] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| Head of performance (preparer) | [@name] | [Approve / Return for correction] | YYYY-MM-DD |
| Independent checker | [@name] | [Decision] | YYYY-MM-DD |
| Chief compliance officer (marketing review) | [@name] | [Decision] | YYYY-MM-DD |
| Performance oversight committee chair | [@name] | [Decision] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | First draft for the year ended [YYYY-12-31] |
| 1.0 | YYYY-MM-DD | [@name] | Example: Approved after independent check and compliance review |
| 1.1 | YYYY-MM-DD | [@name] | Example: Material error corrected in 2023 composite assets; restatement disclosed in section 8 |
Contents
- Firm definition and compliance claim
- Composite description
- Benchmark description
- Annual performance table
- Fee schedule and net-of-fee method
- Calculation methodology
- Valuation and policies
- Significant events, errors and restatements
- Verification status
- Disclosure checklist
- Production workflow and controls
- Glossary and references
1. Firm definition and compliance claim
1.1 Firm definition
| Item | Entry |
|---|---|
| Firm name | [Firm name] |
| Definition | [Legal entity or entities, and the business units included, as presented to clients] |
| Regulatory status | [For example: registered investment adviser; MiFID investment firm] |
| Entities excluded and reason | [Entity: reason] |
| Date the firm definition last changed | [YYYY-MM-DD, or "No change since first claim"] |
| Date compliance was first claimed | [YYYY-MM-DD] |
| Total firm assets at period end | [Currency amount] |
Example: Kestrel Bay Capital is a fictional investment adviser registered with the
SEC. For this report the firm is defined as all discretionary and non-discretionary
assets managed by Kestrel Bay Capital in its New York office. Its EU affiliate, Kestrel
Bay Capital Europe (a MiFID investment firm), is a separate legal entity presented to
clients under its own name and is therefore defined as a separate firm with its own
claim. The fictional Kestrel Bay Global Quality Equity Fund, a UCITS managed by Kestrel
Bay Capital Europe with the same strategy, is therefore not a member of this composite
as shown in Fund Factsheet (finance/fund-factsheet). Total firm assets at 2025-12-31 were
USD 2,480 million.
1.2 Compliance claim placeholder
Insert the compliance statement here only when the firm actually claims compliance and every firm-wide requirement has been met. Copy the wording exactly from the current GIPS standards; do not edit it, shorten it or add qualifiers. If the firm is verified, use the version of the statement for verified firms; if it is not, use the version for firms that have not been verified.
[Insert the compliance statement in the exact wording required by the GIPS standards for this firm's situation.]
If the firm does not claim compliance, delete this subsection and do not describe the report as compliant, "in accordance with" or "consistent with" the standards. A report that only borrows the layout is a marketing piece and must say nothing that implies compliance.
1.3 Trademark notice
Place the trademark notice required by the GIPS trademark guidelines at the foot of the report, in the exact wording given there. Use the registered mark on first use and only as an adjective ("GIPS® standards", "GIPS® Composite Report").
[Insert the trademark notice in the exact wording required by the current GIPS trademark guidelines.]
2. Composite description
2.1 Composite profile
| Item | Entry |
|---|---|
| Composite name and code | [Name] ([CODE]) |
| Description | [Strategy, objective, instruments, typical number of holdings, use of derivatives, leverage and short positions] |
| Composite creation date | [YYYY-MM-DD: when the firm first defined this composite] |
| Composite inception date | [YYYY-MM-DD: start of the performance record] |
| Reporting currency | [Currency] |
| Minimum portfolio size for inclusion | [Currency amount, or "None"] |
| Inclusion rule | [For example: from the first full month under management after funding is complete] |
| Exclusion rule | [For example: from the last full month before termination notice, or when a client restriction makes the portfolio non-discretionary] |
| Significant cash flow policy | [Whether used; threshold; how the portfolio is removed and returned] |
| Composite list availability | [Statement that the list of composite descriptions is available on request] |
Example: The Global Quality Equity Composite (KBC-GQE) contains all fee-paying, discretionary, long-only portfolios that invest in listed developed and emerging market equities of companies with high and stable returns on capital, typically 40 to 60 holdings, unhedged, with no leverage. Derivatives are not used except currency forwards to settle trades. The composite was created on 2016-01-15 and has an inception date of 2016-01-01. The reporting currency is USD. Portfolios below USD 2 million at the start of a month are excluded for that month. New portfolios join at the start of the first full calendar month after they are fully invested; terminated portfolios leave after the last full month before notice. A client contribution or withdrawal of 25% or more of portfolio assets is a significant cash flow: the portfolio leaves the composite for that month and returns at the start of the next month.
2.2 Membership changes since the last annual period
| Change ID | Portfolio | Event | Date | Reason | Approved by |
|---|---|---|---|---|---|
| CMP-CHG-001 (Example) | P-118 | Added | 2026-04-01 | First full month after funding | [@performance-analyst] |
| CMP-CHG-002 (Example) | P-107 | Removed | 2026-08-31 | Client imposed a sector restriction that changes the strategy; portfolio became non-discretionary for this strategy | [@chief-investment-officer] |
| CMP-CHG-003 (Example) | P-111 | Temporarily removed | 2026-06-01 to 2026-06-30 | Withdrawal of 40% of assets, above the 25% significant cash flow threshold | [@head-of-performance] |
| [CMP-CHG-NNN] | [Portfolio] | [Event] | [Date] | [Reason] | [@name] |
Example: no portfolio joined or left the composite during 2025, so the six portfolios in section 4.3 are the whole composite for that year. The log entries above fall in 2026, after the period covered by section 4, and will be reflected in the 2026 annual figures. The log is kept continuously, not only at year end.
Keep the history of every portfolio that has ever been in the composite. A terminated portfolio's past returns stay in the composite for the periods it was included; never remove them retroactively.
3. Benchmark description
| Item | Entry |
|---|---|
| Benchmark name | [Index provider, index name, variant] |
| Return basis | [Total return, net or gross dividends reinvested] |
| Currency | [Currency, hedged or unhedged] |
| Why it is appropriate | [Link to the composite strategy] |
| Benchmark changes | [Date, old benchmark, new benchmark, reason; or "None"] |
| Custom or blended benchmark rules | [Components, weights, rebalancing frequency; or "Not applicable"] |
| Licence for benchmark data | [Licence reference; confirm that the provider allows publication] |
Example: The benchmark is [a broad developed and emerging market equity index], net dividends reinvested, in USD, unhedged. It is the opportunity set from which the strategy selects stocks. The benchmark has not changed since inception. The firm holds a data licence that permits publication of annual benchmark returns in client materials.
Index names and data are usually trademarks and licensed data of the index provider. Use the provider's required attribution line and do not publish index constituent data beyond what the licence allows.
4. Annual performance table
4.1 Annual returns and statistics
All returns are in USD and are total returns including reinvested income. Gross returns are after transaction costs and before management fees. Net returns are after a model management fee (see section 5). Figures for the 3-year annualised standard deviation are calculated from 36 monthly returns held in the calculation workbook.
| Year | Composite gross (%) | Composite net (%) | Benchmark (%) | Composite 3-yr SD (%) | Benchmark 3-yr SD (%) | Number of portfolios | Internal dispersion (%) | Composite assets (USD m) | Firm assets (USD m) | Composite as % of firm |
|---|---|---|---|---|---|---|---|---|---|---|
| 2016 (Example) | 9.12 | 8.30 | 7.86 | N/A | N/A | 3 | N/M | 31.4 | 1,120 | 2.8 |
| 2017 (Example) | 23.85 | 22.92 | 23.97 | N/A | N/A | 4 | N/M | 45.9 | 1,310 | 3.5 |
| 2018 (Example) | -7.41 | -8.10 | -9.41 | 10.62 | 10.94 | 4 | N/M | 47.2 | 1,280 | 3.7 |
| 2019 (Example) | 28.64 | 27.68 | 26.60 | 11.48 | 11.37 | 5 | N/M | 66.0 | 1,540 | 4.3 |
| 2020 (Example) | 17.89 | 17.01 | 16.27 | 17.95 | 18.41 | 6 | 0.84 | 82.7 | 1,760 | 4.7 |
| 2021 (Example) | 20.12 | 19.22 | 18.54 | 16.70 | 17.33 | 6 | 0.71 | 101.3 | 2,050 | 4.9 |
| 2022 (Example) | -15.63 | -16.26 | -18.36 | 19.86 | 20.42 | 7 | 0.93 | 88.6 | 1,890 | 4.7 |
| 2023 (Example) | 21.48 | 20.57 | 22.20 | 16.42 | 16.98 | 6 | 0.58 | 109.5 | 2,140 | 5.1 |
| 2024 (Example) | 14.27 | 13.42 | 17.49 | 15.88 | 16.05 | 6 | 0.66 | 135.0 | 2,310 | 5.8 |
| 2025 (Example) | 11.86 | 11.02 | 13.02 | 12.94 | 13.27 | 6 | 0.63 | 151.2 | 2,480 | 6.1 |
Notes to the table:
- N/A: the 3-year standard deviation is not shown until 36 monthly returns are available.
- N/M: internal dispersion is not shown as meaningful when too few portfolios were in the composite for the full year. State the threshold the firm applies and check it against the GIPS standards.
- Composite and firm assets are at year end. The percentage column is composite assets divided by firm assets (Example: 151.2 / 2,480 = 6.1% for 2025).
- Example: composite assets moved from USD 135.0 million at the end of 2024 to USD 151.2 million at the end of 2025. The 11.86% gross return accounts for USD 16.0 million (135.0 x 0.1186), and net client contributions for the remaining USD 0.2 million; the six portfolios were the same at both dates (section 4.3).
4.2 Annualised returns for the required periods
Marketing rules in several jurisdictions expect standard periods next to the calendar-year table. For a US registered adviser, the SEC Marketing Rule (17 CFR 275.206(4)-1(d)(2)) requires 1-, 5- and 10-year results (or since inception if shorter) ending no earlier than the most recent calendar year end, with equal prominence. Annualised returns are the geometric mean of the annual returns in the window.
| Period to 2025-12-31 | Composite gross (% p.a.) | Composite net (% p.a.) | Benchmark (% p.a.) |
|---|---|---|---|
| 1 year (Example) | 11.86 | 11.02 | 13.02 |
| 5 years (Example) | 9.49 | 8.67 | 9.45 |
| 10 years (Example) | 11.56 | 10.73 | 10.84 |
Example: the 5-year gross figure links 2021 to 2025: 1.2012 x 0.8437 x 1.2148 x 1.1427 x 1.1186 = 1.5737, and 1.5737 to the power 1/5, minus 1, gives 9.49% p.a.
4.3 Internal dispersion worked example
Internal dispersion shows how consistently the strategy was applied across portfolios that were in the composite for the whole year. The firm uses the asset-weighted standard deviation of annual portfolio returns around the composite return; state the measure the firm chose. For simplicity this worked example weights by assets at the start of the year; the production calculation aggregates monthly.
| Portfolio | Beginning assets (USD m) | Weight (%) | 2025 gross return (%) |
|---|---|---|---|
| P-101 (Example) | 48.0 | 35.56 | 12.27 |
| P-102 (Example) | 36.5 | 27.04 | 12.00 |
| P-104 (Example) | 22.0 | 16.30 | 10.83 |
| P-107 (Example) | 15.5 | 11.48 | 11.61 |
| P-111 (Example) | 9.0 | 6.67 | 12.86 |
| P-115 (Example) | 4.0 | 2.96 | 10.17 |
| Total | 135.0 | 100.00 (rounded weights sum to 100.01) | 11.86 (asset-weighted) |
Example: the asset-weighted composite return is 11.86% and the asset-weighted dispersion is 0.63%. For comparison, the equal-weighted population standard deviation of the six returns is 0.90% and the high-low range is 2.69 percentage points (12.86 minus 10.17). The six portfolios were in the composite for all of 2025 (membership did not change during 2025), so they are both the dispersion population and the full composite for the year. Their beginning assets (USD 135.0 million) therefore equal the 2024 year-end composite assets in section 4.1.
4.4 Reconciliation
| Check | Source A | Source B | Difference | Status |
|---|---|---|---|---|
| CHK-001 (Example): 2025 composite gross return | Performance system | Report table | 0.00 | Pass |
| CHK-002 (Example): composite assets 2025-12-31 | Portfolio accounting | Report table | 0.0 | Pass |
| CHK-003 (Example): firm assets 2025-12-31 | Firm AUM register | Report table | 0.0 | Pass |
| CHK-004 (Example): benchmark 2025 | Index provider file | Report table | 0.00 | Pass |
| [CHK-NNN] | [Source] | [Source] | [Value] | [Pass / Fail] |
5. Fee schedule and net-of-fee method
5.1 Current fee schedule
| Assets under management | Annual management fee |
|---|---|
| First USD 25 million (Example) | 0.75% |
| Next USD 75 million (Example) | 0.60% |
| Above USD 100 million (Example) | 0.50% |
| Performance fee | [None / description] |
| Other fees and expenses | [Custody and administration paid by the client directly / included] |
Example: a USD 40 million portfolio pays 0.75% on the first 25 million (USD 187,500) and 0.60% on the next 15 million (USD 90,000), total USD 277,500 a year or 0.69% of assets.
5.2 Net-of-fee method
Example: net returns are calculated by deducting one twelfth of the highest tier fee (0.75% a year) from the gross composite return each month, so the annual model fee compounds:
For 2025: 1.1186 x (1 - 0.000625) to the 12th power = 1.1186 x 0.99253 = 1.1102, so the net return is 11.02%.
Record whether actual or model fees are used, why the chosen model fee is at least as high as the fee a prospective client would pay, and the treatment of performance fees and bundled fees. The SEC staff Marketing Compliance FAQ (updated 2025-03-19 and 2026-01-15) addresses net performance (including net figures that use actual fees when future fees will be higher) and extracted performance; check the current FAQ before publication.
6. Calculation methodology
6.1 Portfolio returns: time-weighted return
The firm calculates portfolio returns as time-weighted returns (TWR). The portfolio is valued on the date of each external cash flow of 10% or more of its value (Example firm threshold) and at each month end. Sub-period returns are linked geometrically, so the timing and size of client contributions and withdrawals do not affect the result.
Here the external cash flow is treated as arriving at the start of sub-period , and is the value just before it arrives.
Example (portfolio P-104, July 2026): beginning value USD 10.00 million on 2026-07-01; value USD 10.25 million at the close of 2026-07-15; contribution of USD 2.00 million at the start of 2026-07-16; ending value USD 12.18 million on 2026-07-31.
| Sub-period | Start value (USD m) | Cash flow (USD m) | End value (USD m) | Return (%) |
|---|---|---|---|---|
| 2026-07-01 to 2026-07-15 (Example) | 10.00 | 0.00 | 10.25 | 2.500 |
| 2026-07-16 to 2026-07-31 (Example) | 10.25 | 2.00 | 12.18 | -0.571 |
| Linked TWR | 1.914 |
Linking: 1.025 x (12.18 / 12.25) = 1.025 x 0.994286 = 1.019143, so the TWR for July is 1.914%.
6.2 Approximation for flows without a valuation
Where a cash flow is below the firm's revaluation threshold, the modified Dietz method weights each flow by the fraction of the period it was invested:
where is the number of days in the period and is the number of days elapsed before flow arrives. Example: applying it to the same July data, the flow arrives after 15 of 31 days, so = 16/31 = 0.5161; the gain is 12.18 minus 10.00 minus 2.00 = 0.18; the return is 0.18 / (10.00 + 2.00 x 0.5161) = 0.18 / 11.0323 = 1.632%. The gap to the true TWR (1.914%) shows why large flows require a valuation.
6.3 Money-weighted return
Money-weighted return (MWR, the internal rate of return) reflects the timing of cash flows and is the usual measure for closed-end private market funds where the manager controls flows. If the composite uses MWR, show it since inception, annualised, with the cash flow frequency.
Example: solving this for July gives a monthly MWR of 1.632%, close to the modified Dietz figure, because modified Dietz is a first-order approximation of the same rate. For this open-ended equity strategy the firm reports TWR, which is the appropriate measure when clients, not the manager, decide on contributions and withdrawals.
6.4 Composite returns
| Item | Firm policy |
|---|---|
| Aggregation method | [For example: asset-weighted using beginning-of-month values plus weighted external cash flows] |
| Frequency | [Monthly, linked geometrically to annual] |
| Treatment of cash and cash equivalents | [Included in portfolio returns] |
| Accrual accounting | [Interest and dividends accrued; dividends recorded on ex-date] |
| Trade-date accounting | [Yes] |
| Withholding taxes | [Returns net of non-recoverable withholding taxes; reclaimable amounts accrued] |
| Risk statistics | [3-year annualised ex-post standard deviation of monthly composite and benchmark returns, population formula, annualised by the square root of 12] |
| Dispersion measure | [Asset-weighted standard deviation of annual returns of portfolios in the composite for the full year] |
7. Valuation and policies
| Topic | Policy summary | Reference |
|---|---|---|
| Valuation sources | [Primary vendor prices; fallback hierarchy; broker quotes for illiquid holdings] | Valuation Policy (compliance/valuation-policy) |
| Fair value overrides | [Committee approval, documentation, back-testing] | [Policy section] |
| Valuation frequency | [Daily accounting; monthly for returns; on large flows] | Section 6 |
| Foreign exchange rates | [Source and fixing time, for example a 16:00 London fix] | [Policy section] |
| Calculation policies | [GIPS policies and procedures manual, version and date] | [Document ID] |
| Availability statement | [Policies for valuing investments, calculating performance and preparing reports are available on request] | Section 10 |
Example: Kestrel Bay Capital values listed equities at the closing price on the primary exchange, converted at the 16:00 London fix. Its valuation committee approves any override and reviews stale prices weekly.
8. Significant events, errors and restatements
8.1 Significant events
| Event ID | Date | Event | Effect on the record | Disclosed until |
|---|---|---|---|---|
| EVT-001 (Example) | 2024-06-30 | Co-portfolio manager retired; successor had co-managed since 2021 | None on the process; disclosed for transparency | [YYYY-12-31] |
| EVT-002 (Example) | 2025-01-01 | Moved to a new portfolio accounting system | Parallel run for six months; no differences above 1 basis point | [YYYY-12-31] |
| [EVT-NNN] | [Date] | [Event] | [Effect] | [Date] |
8.2 Error correction log
| Error ID | Found | Period affected | Description | Materiality (per policy) | Action |
|---|---|---|---|---|---|
| ERR-001 (Example) | 2026-02-10 | 2023 | Composite assets overstated by USD 4.1 million (a terminated portfolio left in the year-end total) | Material under the firm's policy threshold for asset figures | Restated; disclosure added; report redistributed to prospective clients who received it in the last 12 months |
| [ERR-NNN] | [Date] | [Period] | [Description] | [Material / Not material] | [Action] |
Define materiality in the firm's error correction policy (for example, by size of the change and whether it would alter a reader's view). Keep the disclosure for the period the policy and the standards require.
9. Verification status
| Item | Entry |
|---|---|
| Verifier | [Firm name] |
| Verification period | [YYYY-MM-DD to YYYY-MM-DD] |
| Date of latest verification report | [YYYY-MM-DD] |
| Performance examination of this composite | [Yes, period YYYY to YYYY / No] |
| Statement placement | [Insert the verification wording exactly as required by the GIPS standards] |
Example: Kestrel Bay Capital has been verified for the periods 2016-01-01 to 2025-12-31. The Global Quality Equity Composite has not had a performance examination. The verification report is available on request.
10. Disclosure checklist
Tick each item only after comparing the report with the official source. This list is original to this template and is not the list of GIPS provisions; obtain the standards for the authoritative list.
| ID | Item to confirm | Source to check | Present |
|---|---|---|---|
| DSC-001 | Compliance statement, exact wording for the verification status | GIPS standards | [Yes / No] |
| DSC-002 | Firm definition, and date of any change | GIPS standards | [Yes / No] |
| DSC-003 | Composite description, creation date and inception date | GIPS standards | [Yes / No] |
| DSC-004 | Benchmark description, and changes with dates and reasons | GIPS standards | [Yes / No] |
| DSC-005 | Currency of returns and statistics | GIPS standards; Delegated Reg (EU) 2017/565 Art. 44(4)(e) for EU retail | [Yes / No] |
| DSC-006 | Gross and net returns, with the fee and expense basis of each | GIPS standards; 17 CFR 275.206(4)-1(d)(1) | [Yes / No] |
| DSC-007 | Fee schedule appropriate to the prospective client | GIPS standards | [Yes / No] |
| DSC-008 | Risk statistic and dispersion measure, and their definitions | GIPS standards | [Yes / No] |
| DSC-009 | Number of portfolios, composite assets and total firm assets | GIPS standards | [Yes / No] |
| DSC-010 | Availability of the composite list and of the policies | GIPS standards | [Yes / No] |
| DSC-011 | Use of leverage, derivatives and short positions, if material | GIPS standards | [Yes / No] |
| DSC-012 | Significant cash flow policy, if used | GIPS standards | [Yes / No] |
| DSC-013 | Significant events and material error disclosures | GIPS standards; firm policy | [Yes / No] |
| DSC-014 | Trademark notice, exact wording | GIPS trademark guidelines | [Yes / No] |
| DSC-015 | 1-, 5- and 10-year (or since inception) periods with equal prominence | 17 CFR 275.206(4)-1(d)(2) | [Yes / No] |
| DSC-016 | No statement implying regulator approval of the figures | 17 CFR 275.206(4)-1(d)(3) | [Yes / No] |
| DSC-017 | Past-performance warning, reference period and source (EU, UK clients) | Delegated Reg (EU) 2017/565 Art. 44(4); FCA rules; GIPS standards (check) | [Yes / No] |
| DSC-018 | Benchmark provider attribution line | Index licence | [Yes / No] |
11. Production workflow and controls
| Control ID | Control | Frequency | Owner | Evidence |
|---|---|---|---|---|
| PCR-CTL-001 (Example) | Membership changes approved against written inclusion and exclusion rules | Monthly | [@head-of-performance] | Signed change log (section 2.2) |
| PCR-CTL-002 (Example) | Independent recalculation of annual composite returns from monthly portfolio returns | Annual | [@independent-checker] | Recalculation workbook |
| PCR-CTL-003 (Example) | Reconciliation of composite and firm assets to portfolio accounting | Annual | [@fund-accounting] | Reconciliation (section 4.4) |
| PCR-CTL-004 (Example) | Marketing review of the final report and every extract | Each distribution | [@chief-compliance-officer] | Marketing Review Checklist record |
| PCR-CTL-005 (Example) | Distribution log of prospective clients who received the report | Continuous | [@client-service] | CRM extract |
| [PCR-CTL-NNN] | [Control] | [Frequency] | [@owner] | [Evidence] |
Keep the records that support each figure (portfolio valuations, transactions, membership decisions and calculations) for at least the period required by the firm's record-keeping rules; for a US adviser, check the books and records rule (17 CFR 275.204-2).
12. Glossary and references
12.1 Glossary
| Term | Meaning in this document |
|---|---|
| Composite | The set of portfolios that the firm reports together as one track record because they follow the same strategy |
| Firm | The organisation, as it presents itself to clients, whose total assets and policies the compliance claim covers |
| Time-weighted return (TWR) | Return that removes the effect of external cash flows by linking sub-period returns |
| Money-weighted return (MWR) | The single rate that equates beginning value and cash flows with the ending value; also called internal rate of return |
| Modified Dietz | An approximation of the money-weighted return that weights each flow by the time it was invested |
| Gross return | Return after transaction costs, before management fees |
| Net return | Return after management fees (actual or model) |
| Internal dispersion | A measure of how widely the returns of individual portfolios in the composite vary around the composite return |
| 3-year standard deviation | Annualised volatility of the last 36 monthly returns |
| Verification | An engagement by an independent third party that covers the whole firm and tests how composites are built and how performance is calculated and presented; it gives no assurance on any single composite's figures |
| Performance examination | A separate independent engagement on one composite or pooled fund |
12.2 References
| Reference | Version or date | Use |
|---|---|---|
| GIPS standards for Firms (name only) | 2020 edition, effective 2020-01-01; check for later editions and guidance statements | Compliance claim, statements and required items, inserted by the firm from the official text |
| GIPS trademark guidelines (name only) | Current version on the official site | Trademark notice |
| SEC Investment Adviser Marketing Rule, 17 CFR 275.206(4)-1 | As in force 2026-10 | Paragraph (d) performance conditions |
| SEC Division of Investment Management, Marketing Compliance FAQ | Updated 2025-03-19 and 2026-01-15 | Net performance with actual fees, extracted performance |
| 17 CFR 275.204-2 (books and records) | As in force 2026-10 | Record retention |
| Commission Delegated Regulation (EU) 2017/565, Article 44 | As amended; check the consolidated text | Past performance in client information (EU) |
| Regulation (EU) 2019/1156, Article 4, and ESMA guidelines on marketing communications (ESMA34-45-1272) | Guidelines applied from 2022-02-02 | Marketing communications for funds (EU) |
| Brinson, Hood and Beebower (1986); Brinson and Fachler (1985) | Journal articles, cited by name | Attribution (see the attribution report) |
Standard and licence note
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