Composites: Inclusion and Exclusion of Portfolios

The GIPS standards for constructing composites mandate the timely and consistent inclusion of new portfolios once they are managed. Firms must create, document, and consistently follow a policy for adding new portfolios to the relevant composites promptly. In many cases, new portfolios should be added at the start of the next complete performance measurement period after the firm receives the funds.

Illiquid Holdings or Strategies Which Require Time to Implement

When managing illiquid assets or strategies that require time for proper implementation, there might be a delay in investing new portfolio assets in line with the desired strategy. The GIPS standards provide firms with flexibility to decide when to include such portfolios in a composite. If firms opt for this flexibility due to the gradual nature of investing with the new strategy, they must establish a policy for each composite and consistently apply it to all new portfolios.

Winning and Losing Business

When firms gain new clients, they also often lose existing relationships. According to the GIPS standards, when a firm loses a client and terminates a portfolio, that terminated portfolio’s historical performance must be included in the composite’s performance record. This inclusion continues until the last full measurement period in which the firm had control over managing the portfolio in line with its strategy.

Losing Business Example

Let’s say a firm calculates performance monthly. If they receive notice on December 20th that they will lose a client by December 31st and are told to stop trading, they should include the portfolio in their composite only through November 30th. This means they step back one month. They do this because they didn’t have full discretionary control over the assets for the partial month of December. This ensures that the partial period in December doesn’t negatively affect their performance results.

A Written Policy is Needed in Advance

Regardless of the circumstances, GIPS-compliant firms must have clear and documented policies for removing terminated portfolios from composites. It’s crucial to establish these policies in advance and ensure consistent application.

Adding, Removing, and Switching Portfolios

GIPS-compliant firms need written policies that specify when portfolios can be added to or removed from composites, and these policies should be specific to each composite.

Example Policy for a Firm Reporting Monthly

“All new portfolios funded with cash or securities on or before the 15th day of the month shall be added to the appropriate composite at the beginning of the following month. All new portfolios funded with cash or securities after the 15th day of the month shall be added to the appropriate composite at the beginning of the second month after funding. All terminating portfolios will be removed from the composite at the end of the last full month for which the firm has full discretion. The historical performance of terminated portfolios shall remain in the appropriate composite.”

These policies allow firms a reasonable amount of time to implement the strategy without delaying inclusion of the portfolio in the appropriate composite.

Developing a Written Policy in Advance

Each firm must develop a policy that conforms to its own investment process while meeting the GIPS standards requirement to include portfolios in composites on a timely basis. Here is a sample statement for a policy:

“Portfolios shall not be moved from one composite to another unless the composite is redefined or documented changes in the client’s guidelines require restructuring the portfolio in such a way that another composite becomes more appropriate. The portfolio shall be removed from the original composite at the end of the last calendar month before the event causing the removal occurred and shall be added to the appropriate new composite at the beginning of the calendar month following the date on which the portfolio is substantially invested. The historical performance of the portfolio shall remain in the original composite.”

Criteria for Switching a Portfolio to a New Composite

The GIPS standards set clear criteria for switching a portfolio to a new composite. Portfolios can only be moved if there are documented changes in the portfolio’s investment mandate, objective, or strategy, or if the composite itself is redefined in a way that justifies the switch.

Importantly, the historical performance of the portfolio must remain in the original composite. This requirement prevents unethical practices where a firm could manipulate reported performance by moving portfolios selectively between composites to boost results.

The GIPS standards describe two conditions under which portfolios can be reassigned.

1. “A portfolio can be switched from one composite to another if the client revises the mandate, objective, or strategy governing the investment of portfolio assets and the guideline changes are documented.

   For example, a client might decide to modify the portfolio mandate from mid-cap value to large-cap value, or from domestic equity to global equity, with a corresponding change in the benchmark, while retaining the same investment advisor to restructure and manage the “same” portfolio in accordance with the new strategy.”

2. “A portfolio can be reassigned to another composite if the original composite is redefined in such a way that the portfolio no longer fits it.

   Generally, if a strategy changes over time, it is most appropriate to create a new composite; accordingly, the redefinition of an existing composite should be a highly unusual event.”

Significant Cash Flows

In cases of significant cash flows, a portfolio may be temporarily excluded from the composite.

Defining Significant Cash Flows

A significant cash flow refers to a substantial client-directed transfer of funds that could temporarily hinder the firm’s ability to execute its investment strategy.

In line with GIPS principles, firms must establish a composite-specific definition of “significant” before such events occur and consistently apply this definition. Ex-ante, meaning “before the event,” ensures that rules aren’t adjusted after the fact to manipulate results.

Alternatively, firms can create temporary new accounts to isolate the impact of significant cash flows. In this approach, client-initiated cash and securities are placed in a temporary account not included in any composite until the external cash flows align with the portfolio’s investment strategy. They are then moved to the main portfolio and treated as external cash flows. Likewise, when clients initiate large withdrawals, the firm transfers the appropriate cash and securities to a temporary account until the securities are liquidated and the funds are disbursed. This transfer is considered an external cash outflow when calculating the portfolio’s time-weighted total return.

Minimum Asset Levels

Firms have the option to omit portfolios from a particular composite if their value drops below a predetermined limit. This choice may stem from the belief that the investment strategy works best for larger portfolios.

Portfolios that fall beneath this minimum asset level are considered non-discretionary within that specific composite. If a firm establishes such a minimum, it must also develop documented policies that specify how portfolios below this threshold will be handled.

Minimum Asset Levels Example Policy

A firm can choose to take portfolios out of a composite the month after they drop below the minimum asset level. For instance, if the firm sets a minimum asset requirement of $2 million for adding a portfolio to a composite, it may decide not to remove a portfolio from that composite unless its assets fall below $1,900,000.

It’s important to note that any changes made to the minimum asset level for a specific composite should not be applied retroactively, as per the GIPS standards.

When a portfolio is removed from a composite due to falling below the minimum, its past performance must still be retained within the composite. The firm must also assess if the removed portfolio qualifies for any other composite and include it accordingly in a consistent and timely manner.

This practice helps prevent a form of survivorship bias in the firm’s performance reporting. It ensures that clients are informed about portfolios that have not performed well and have experienced a decline in asset value, preventing unfavorable results from being concealed.

Question

If a firm that calculates performance monthly is informed on January 20^th that its it is losing a client effective January 31^st and is instructed to stop trading from that point. In this case, the firm should most likely include the portfolio in its composite through which date?

1. December 31^st.
2. February 29^th.
3. January 20^th.

Solution:

The correct answer is A.

Going back one month, to the last complete month of the preceding year, is a fair approach to showcase results. It only evaluates the firm’s performance for full periods during which it had an opportunity to execute its strategy.

B and C are incorrect. Answer choice C appears to be a logical option, as does answer choice B. The issue with including performance up to those dates is that the firm didn’t have a complete measurement period to implement its strategy, and this may have been adversely impacted by the client loss.

Reading 33: Global Investment Performance Standards

Los 33 (g) Explain requirements of the GIPS standards with respect to composite construction, including switching portfolios among composites, the timing of the inclusion of new portfolios in composites, and the timing of the exclusion of terminated portfolios from composites