INVESTMENT PERFORMANCE COUNCIL (IPC) Guidance Statement on Calculation Methodology

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1 Adoptio Date: 4 March 2004 Effective Date: 1 Jue 2004 Retroactive Applicatio: No Public Commet Period: Aug Nov 2002 INVESTMENT PERFORMANCE COUNCIL (IPC) Preface Guidace Statemet o Calculatio Methodology The Ivestmet Performace Coucil (IPC) has stated its itetios to trasform the curret Global Ivestmet Performace Stadards (GIPS ) ito gold stadards which will represet global best practices for historical performace calculatio ad presetatio. The IPC has agreed to follow a evolutioary approach for developmet of the GIPS stadards, which icludes a strategy of ot itroducig sigificat chages to the GIPS stadards before This strategy is desiged to maitai a sesible balace betwee improvig the GIPS stadards while avoidig udue disruptio to firms that are, or are i the process of, claimig compliace. Curretly, the gold GIPS Stadards (which do icorporate all provisios relatig to this guidace statemet) are out for a period of public commet. Durig the secod half of 2004, the IPC will be aalyzig all public commets ad potetially alterig gold GIPS based o the feedback from the idustry. With regards to calculatio methodology, curret GIPS Provisio 1.A.6 reads as follows: Accrual accoutig must be used for divideds (as of the ex divided date) for periods begiig 1 Jauary As a result of the IPC s aalysis of curret GIPS requiremets, the 1 Jauary 2005 effective date for accrual accoutig of divideds was deemed impractical due to the fact that most portfolio maagemet systems ad techology do ot accrue divideds. I order to maitai a practical approach to evolvig the Stadards, the IPC agreed to move this effective date ito the future. Firms are ot expected to implemet GIPS Provisio 1.A.6 i 2005 as curretly stated i the GIPS stadards. Although this provisio is ow curretly proposed (i the gold GIPS draft) to become a requiremet o or before 2010, firms are strogly ecouraged to adopt the ifrastructure ecessary to implemet this provisio as soo as possible. Because movig the date to 1 Jauary 2010 is oly proposed ad is ot expected to be fialized util 2006 with the release of the fial gold GIPS stadards, the followig Guidace Statemet will reflect both what the curret GIPS stadards require ad what is proposed uder the gold GIPS revisios. This Guidace Statemet takes effect o 1 Jue After 1 Jue 2004, firms must follow this guidace, regardless of what effective date is chose for GIPS provisio 1.A

2 The gold GIPS proposal is curretly available for public commet through 1 August 2004 o the AIMR Website at Itroductio Achievig comparability amog ivestmet maagemet firms performace presetatios requires uiformity i the methods used to calculate returs. Although the GIPS stadards allow flexibility i retur calculatio, the retur must be calculated usig a methodology that icorporates the time-weighted rate of retur cocept. The stadards require a time-weighted rate of retur because it removes the effects of cash flows, which are geerally cliet-drive. By removig the effects of cash flows, a time-weighted rate of retur best reflects the firm s ability to maage the assets accordig to a specified strategy or obective ad is the basis for the comparability of composite returs. O 1 Jauary 2010 it is curretly proposed i gold GIPS that a true Time-Weighted Retur will become a requiremet. Firms may use alterative approximatios to the true Time- Weighted Retur prior to 1 Jauary 2010 provided the calculatio method chose represets returs fairly, is ot misleadig, ad is applied cosistetly. It should be oted that the retur calculatio is depedet o accurate ad cosistet iput data which is also critical to effective compliace with GIPS. I this guidace statemet, the term retur is used rather tha the more commo term performace to emphasize the distictio betwee retur ad risk ad to ecourage the view of performace as a combiatio of risk ad retur. Risk measures are valuable tools for assessig the abilities of asset maagers; however, this guidace statemet focuses oly o retur calculatio. Moey- or dollar-weighted returs may add further value i uderstadig the impact to the cliet of the timig of exteral cash flows, but are less useful for compariso ad are therefore ot covered by this guidace statemet. Guidig Priciples Calculatio Priciples The followig are guidig priciples that firms must use whe calculatig portfolio ad composite returs: Firms must calculate total returs. Total returs must iclude icome as well as realized ad urealized gais ad losses. Firms must calculate returs after the deductio of all tradig expeses. Firms must calculate returs at least o a mothly basis. For periods prior to 2001, firms may calculate portfolio returs o a quarterly basis. For periods prior to 2006, firms may calculate composite returs o a quarterly basis; however, it is recommeded that firms calculate composite returs o a mothly basis

3 Firms must use time-weighted rates of retur that adust for cash flows, where a "cash flow" is a exteral flow of cash ad/or securities (capital additios or withdrawals) that is cliet iitiated. Firms must lik the periodic returs geometrically. Composites must be asset-weighted usig begiig-of-period weightigs or a method that reflects both begiig market value ad cash flows. Valuatio Priciples The followig are guidig priciples that firms must use whe determiig portfolio values as the basis for the retur calculatio: Portfolio valuatios must be based o market values (ot cost basis or book values). Accrual accoutig must be used for fixed icome securities ad all other assets that accrue iterest icome. Accrual accoutig must be used for divideds (as of the ex divided date) for periods begiig 1 Jauary (proposed to chage to 1 Jauary 2010 i gold GIPS) Accruals must be icluded i the market value calculatio of the deomiator ad the umerator. Firms must use trade-date accoutig for periods begiig 1 Jauary Time-Weighted Rate Of Retur Valuig the portfolio each time there is a exteral cash flow ought to result i the most accurate method to calculate the time-weighted rates of retur, referred to as the true Time-Weighted Rate of Retur Method. Begiig 1 Jauary 2010, this methodology is proposed i gold GIPS to be required. Util 2010, approximatio methods are permitted. A formula for calculatig a true time-weighted portfolio retur wheever cash flows occur is: R TR ( EMV BMV ), BMV where EMV is the market value of the portfolio at the ed of the sub-period, before ay cash flows i the period, but icludig accrued icome for the period. BMV is the market value at the ed of the previous sub-period (i.e., the begiig of the curret sub-period); icludig ay cash flows at the ed of the previous sub-period ad icludig accrued icome up to the ed of the previous period. The sub-period returs are the geometrically liked accordig to the followig formula: (( 1 + R ) ( 1 + R )...( 1 + R )) 1 R, TR

4 where R TR is the total retur ad R 1, R 2 R are the sub-period returs for sub-period 1 through respectively. Sub-period 1 exteds from the first day of the period up to ad icludig the date of the first cash flow. Sub-period 2 begis the ext day ad exteds to the date of the secod cash flow, ad so forth. The fial sub-period exteds from the day after the fial cash flow through the last day of the period. This method assumes that the cash flow is ot available for ivestmet util the begiig of the ext day. Accordigly, whe the portfolio is revalued o the date of a cash flow, the cash flow is ot reflected i the Edig Market Value, but is added to the Edig Market Value to determie the Begiig Market Value for the ext day. If the cash flow is available for ivestmet at the begiig of the day the value of the cash flow should be added to the Begiig Market Value. Note that some day-weightig methods assume the cash flow is available midday ad half weight the cash flow i that day. The GIPS stadards do ot specify which cash flow recogitio method firms must use; however, oce a method(s) is chose ad the criteria ad assumptios are determied, they must be cosistetly applied. Approximatio Of Time-Weighted Rate Of Retur As metioed i the Itroductio, the GIPS stadards require firms to calculate returs usig a methodology that icorporates the time-weighted rate of retur cocept. The GIPS stadards allow flexibility i choosig the calculatio methodology, which meas that firms may use alterative formulas. Calculatig a true time-weighted rate of retur is ot a easy task ad may be very cost itesive. For these reasos, firms may use a approximatio method to calculate the total retur of the idividual portfolios for the periods ad sub-periods. The most commo approximatio methods combie specific rate of retur methodologies (such as the origial Dietz method, the Modified Dietz method, the origial Iteral Rate of Retur (IRR) method, ad the Modified IRR method) for sub-periods ad icorporate the time-weighted rate of retur cocept by geometrically likig the sub-period returs. The mai differece betwee the various methods is the calculatio of the average capital ivested, which is the deomiator used to calculate the retur of a specific sub-period. Depedig o the specific method, the average ivested capital is based o differet weights of the cash flows. Just as the GIPS stadards trasitio to more frequet valuatios, the stadards also trasitio to more precise calculatio methodologies. Therefore, the GIPS stadards require firms to calculate approximated time-weighted rates of retur that adust for daily-weighted cash flows by 1 Jauary 2005 (e.g., Modified Dietz method) ad will likely require the calculatio of true timeweighted rates of retur with valuatios occurrig at each exteral cash flow by 1 Jauary This guidace statemet does ot cotai details o the differet formulas for calculatig approximate time-weighted rates of retur. Composite Retur Calculatio - 4 -

5 The GIPS stadards state that composites must be asset-weighted usig begiig-of-period weightigs or a method that reflects both begiig market value ad cash flows. The itetio is to show a composite retur that reflects the overall retur of the set of the portfolios icluded i the composite. To calculate composite returs, firms may use alterative formulas so log as the calculatio method chose represets returs fairly, is ot misleadig, ad is applied cosistetly. The GIPS stadards require asset weightig of the portfolio returs withi a composite usig begiig-of-period weightigs, begiig-of-period market values plus weighted cash flows, or by aggregatig portfolio assets ad cash flows to calculate performace as a sigle master portfolio. Accordig to the Begiig Market Value-Weighted Method the composite retur, R BMV, ca be calculated usig the formula ( BMV R ) i i R BMV BMVTOTAL 1, i where BMV i is the begiig market value (at the start of the period) for a portfolio, R i is the rate of retur for Portfolio i, ad BMV TOTAL is the total market value at the begiig of the period for all the portfolios i the composite. The Begiig Market Value Plus Cash Flow-Weighted Method represets a refiemet to the asset-weighted approach. Cosider the case i which oe of two portfolios i a composite doubles i market value as the result of a cotributio o the third day of a performace period. Uder the asset-weighted approach, this portfolio will be weighted i the composite based solely o its begiig market value (i.e., ot icludig the cotributio). The begiig market value ad cash flow-weighted method resolves this problem by icludig the effect of cash flows i the weightig calculatio as well as i the market values. Assumig that cash flows occur at the ed of the day, the weightig factor for each cash flow is calculated as: W i, ( CD D ) i,, CD where CD is the total umber of caledar days i the period ad D i, is the umber of caledar days sice the begiig of the period i which cash flow occurred i portfolio i. The begiig market value plus cash flow-weighted composite retur, R BMV+CF, ca be calculated as follows: R BMV + CF i m {( BMVi + ( CF ) } i, Wi Ri m ( BMVi + ( CFi, Wi ) 1 1, i 1 1,, - 5 -

6 where CF i, is the cash flow withi the period for portfolio i (cotributios to the portfolio are positive flows, ad withdrawals or distributios are egative flows) ad R i is the retur for portfolio i. The Aggregate Retur Method combies all the composite assets ad cash flows before ay calculatios occur to calculate returs as if the composite were oe portfolio. The method is also acceptable as a asset-weighted approach. Geometric Likig Of The Periodic Composite Returs To calculate the composite retur over more tha oe (sub-)period, the composite retur over the total period is calculated by geometrically likig the idividual composite sub-period returs usig the followig formula: (( 1 + R ) ( 1 + R )... ( 1 + R )) 1 R CT C1 C 2 C, where R CT is the composite retur over the total period ad R C1, R C2, ad R C are the idividual composite returs for the sub-periods 1, 2, ad, respectively. Additioal Cosideratios Chages To The Methodology Firms should disclose which retur calculatio methodology is applied ad whether there have bee ay chages to the calculatio methodology. Third-Party Performace Measuremet Firms may use portfolio returs calculated by a third-party performace measurer as log as the formula adheres to the requiremets of GIPS stadards. Differet Valuatio Ad/Or Calculatio Methods Firms are permitted to iclude portfolios with differet valuatio ad/or calculatio methodologies withi the same composite (as log as the formulas adhere to the requiremets of GIPS stadards). Firms must be cosistet i the methodology used for a portfolio (e.g., firms caot chage the methodology for a portfolio from moth-to-moth). Moth Ed Valuatios Firms must be cosistet i defiig the (mothly) valuatio period. The valuatio period must ed o the same day as the reportig period. I other words, firms must value the portfolio/composite o the last day of the reportig period (or the earest busiess day). Aggregatig portfolios with differet edig valuatio dates i the same composite is ot permitted after 1 Jauary 2006 (Proposed i gold GIPS stadards to become effective o this date). Tradig Expeses Returs must be calculated after the deductio of all tradig expeses

7 Trade Date Accoutig Trade-date accoutig is recommeded whe calculatig returs, although settlemet-date accoutig is acceptable if disclosed. Firms must use trade-date accoutig for periods begiig 1 Jauary Trade date accoutig recogizes a asset or liability o the date the trasactio is etered ito. As a result, the accout will recogize ay chage betwee the price of the trasactio ad the curret market value. Taxes Firms must disclose relevat details of the treatmet of withholdig tax o divideds, iterest icome, ad capital gais. Returs should be calculated et of o-reclaimable withholdig taxes o divideds, iterest, ad capital gais. Reclaimable withholdig taxes should be accrued. Grossig-Up Or Nettig-Dow Of Ivestmet Maagemet Fees Firms are allowed to iclude portfolios with differet grossig-up methodologies withi the same composite. Firms must be cosistet i the methodology used for a portfolio (e.g., firms caot chage the methodology for a portfolio from moth-to-moth). Large Cash Flows Firms usig approximatio methods are permitted to adust returs to accout for large exteral cash flows, provided the adustmets are treated i a cosistet maer. The firm must establish a policy o defiig ad adustig for large cash flows ad apply this policy cosistetly. Actual valuatios at the time of ay exteral cash flows will likely be required for periods begiig 1 Jauary Disclosures Firms are ecouraged to make all policies ad iformatio available o request that are ecessary to fully uderstad the calculatio of the portfolio ad composite returs. Effective Date This Guidace Statemet is effective 1 Jue Firms curretly comig ito compliace should apply this guidace to all periods. Firms are ecouraged to apply this guidace prior to the Effective Date

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