Investment Performance Solutions
Regulators continue to focus on investment performance, both from an advertising perspective as well as with regard to the completeness and accuracy of data used to support reported investment returns.
In addition to Global Investment Performance Standards (GIPS®) verification, ACA offers a variety of performance solutions that aid firms with performance calculation methodology reviews and assessment of control and oversight framework.
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We provide an in-depth forensic review of a firm’s compliance structure for calculating and substantiating investment performance. In addition, this review assesses whether the firm’s controls governing performance reporting would stand up to regulatory scrutiny.
Our review also assists with the execution of the firm’s compliance program by assessing risks and gaps in internal performance processes.
We provide an independent third-party review and examination of input data, methodologies, and assumptions used to support an investment performance track record. This solution is designed to bring credibility to the historical track record by examining your adherence to disclosed methodologies and results in a tailored performance certification report that may be shared with the marketplace.
We provide skilled resources on a short to long-term basis to assist firms during times of need, such as personnel transitions or extended absences. We also can assist firms on a routine basis in order to provide fresh perspectives and insight on your firm’s performance program.
Why choose a Focused Performance Review?
- Assesses risks and gaps in internal controls related to the generation and distribution of investment performance.
- Identifies weaknesses in your firm's ability to locate and provide the books and records used to support underlying portfolio and strategy-level performance in a timely manner, particularly when long track records are built across multiple systems or spreadsheets.
- Helps avoid regulatory pitfalls. When a firm inconsistently uses performance information across different parts of the business, or through consultants or affiliates, marketing materials can be deemed misleading, especially if they fail to properly reflect performance and do not include complete and accurate disclosures.
- Reviews the calculation methodologies for internal rate of return (IRR) for investments or funds in accordance with FINRA Regulatory Notice 20-21
Why choose a Performance Certification?
- Provides assurance and lends additional credibility to the underlying track record.
- Opens doors to certain advisory platforms for performance marketing purposes.
- Certifications are not bound by the GIPS standards and therefore provide more flexibility when determining the scope of an engagement.
- Provides a framework that helps strengthen a firm's internal controls and mitigates regulatory risks related to investment performance.
Our unique perspective is informed by our real-world experience, deep subject matter expertise, and extensive client network.
The New Marketing Rule’s Impact on the Presentation of Performance
The long-awaited modernization of the Marketing Rule was added to the Federal Register on March 5, 2021. Not only does the final marketing rule consolidate the advertising and cash solicitation rules, it also (among other things) categorizes certain considerations for presenting investment performance, effectively streamlining guidance currently found across multiple staff letters.
- SEC Marketing Rule
FINRA Leverages the GIPS Standards for Standardizing Private Placement Performance Marketing
FINRA's release of Regulatory Notice 20-21 allows the use of IRR for investments or funds that have been fully realized but further requires utilizing the calculation methodologies of the Global Investment Performance Standards (GIPS) for investment programs/funds that include both realized and unrealized holdings.
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