In a comment letter last week, ABA offered feedback on the CFA Institute’s proposed changes to the Global Investment Performance Standards, a voluntary disclosure regime for investment managers. GIPS disclosures are used by some banks to report on the investment performance of bank-sponsored collective investment funds.
The proposed amendments, known as GIPS 2020, would go into effect January 1, 2020 and could result in burdensome, duplicative and inconsistent disclosure requirements for bank-sponsored CIFs — without offering new information to investors, ABA noted. The association urged the CFA Institute to acknowledge the existing disclosure framework imposed on bank-sponsored CIFs, and requested flexible treatment for these funds.