What are the mandatory composite construction rules under GIPS, and why do composites matter?
I'm studying GIPS for CFA and I understand composites are groups of portfolios, but I'm unclear on the exact rules for which portfolios must be included. Can a firm cherry-pick its best performers into a composite?
Composites are the backbone of GIPS because they prevent exactly the kind of cherry-picking you described. GIPS mandates specific construction rules to ensure fair, comparable performance reporting.
What Is a Composite?
A composite is an aggregation of one or more portfolios managed according to a similar investment mandate, objective, or strategy. Every discretionary, fee-paying portfolio must be included in at least one composite.
Mandatory Construction Rules
- All actual, discretionary, fee-paying portfolios must be included in at least one composite
- Composites must be defined before the period of performance — no after-the-fact grouping
- New portfolios must be included in the composite on a timely and consistent basis (the firm's policy must specify the inclusion timing, e.g., first full month)
- Terminated portfolios must remain in the historical composite record through the last full measurement period
- Non-discretionary portfolios are excluded (the firm cannot control these portfolios)
- Portfolios must not be switched between composites unless documented changes in investment mandate justify it
Anti-Cherry-Picking Provisions
The key anti-cherry-picking features:
- Firms cannot exclude portfolios from composites based on performance
- Portfolio inclusion criteria must be established in advance
- If a client constrains the mandate (making it non-discretionary), the portfolio can be removed, but this must be documented
- Simulated or model portfolios are never included in composites
Minimum Number of Portfolios
If a composite has five or fewer portfolios, the firm is not required to present a measure of internal dispersion. However, the composite must still be maintained and presented.
Practical Example — Ridgecrest Asset Management
Ridgecrest runs a US Large Cap Value strategy. They have 47 client portfolios following this strategy. They cannot pick the top 20 performers and call that the composite — all 47 must be included. If Portfolio #23 lost 15% while the rest averaged +8%, that poor performer stays in the composite.
Exam tip: GIPS composite questions focus on what must be included, when portfolios enter/exit, and the prohibition on retroactive composite creation.
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