KiwiSaver measurement standards put out to tender

Re penultimate paragraph, why will the successful tenderer be an accounting firm? What expertise do accountants have in performance measurement of managed funds? They don't even audit the unit price of a fund as part of the annual audit! Is this just another case of the consultant, when asked to tell you the time, borrows your watch from you, tells you the time, charges you plenty and then keeps your watch?

What you should understand Murray is that globally, CA firms play a huge role in the mutual funds industry and so are ideally placed to recommend a "global best practise" standard for the NZ industry. "NZ best practise" is no longer good enough - its time to raise the bar.

I hope they realise that any measurement will have to be released to the public to allow comment before final implementation.

What's the bar called that's set by the CAs for global best practise? The Enron Bar, or the more recent Lehman Threshold? History would in fact suggest that CA's are not the best watch-dogs for the finance industry.

Aren't there already Global Investment Performance Standards (GIPS) established by the CFA Institute and adopted in many advanced economies? If so, why would little ol' NZ need to spend investors money on reinventing the wheel?

I imagine the plan is to use the CA firms to find global best practise standards not actually invent them or act as watch-dogs for them. Re GIPS - its a set of standards that work at a company level and is not appropriate for retail mutual fund performance measurement, not at least in a meaningful investor friendly way.

I think accountants are necessary as the crux of the performance issue comnes down to the construction of the unit price. What should and shouldnt be part of the unit price is the big question. What fees should be taken out? What about dollar based fees? Should they even exist? What about unlisted, unpriced assets?

GIPS sets out a global minimum standard, not the global best practice. To be GIPS compliant, a managers stated returns have to adher to the GIP standard OR the local standard, whichever are more strict. We should strive for something that is, at a minimum, GIPS compliant, but where we can do better, we should.

Why is the ISI driving this instead of the regulator (choose which one). A measurement of performance needs far more information to be disclosed than that which is currently provided by the funds management industry. Investors should be able to easily assess not only the result of their investment over any period but also the risks being taken to achieve that performance. Anecdotal data suggests the public, and retail investors in particular, have diminished trust in the sector because of a continual stream of stunning revelations and poor results. And why are these standards being considered only for Kiwisaver? It is time to adopt performance reporting standards for all investments. Let's also address fund managers ability to report only six month or one year investment results in marketing material - reminiscent of psychology-driven finance company advertising. Equally important is legislative demand for full disclosure of all fees including those of feeder structures between the investor and the end use of their funds; auditing of unit pricing; full disclosure of all related party transactions and reserving policies plus the number and frequency of transactions. This is not a comprehensive list. Trust needs to be rebuilt and sunlight into the deepest recesses of the industry is the best form of disinfectant likely to achieve that. Lets not miss this opportunity to do so.

The Big 4 Accounting firm do a lot of GIPS verification work globally (using CFA charterholders) and so would be able to tap into that knowledge base of what would be appropriate. NB there is the issue that under GIPS, you can't be selective about which funds are in compliance - the entire "firm" has to be in compliance, which is not always an easy task for NZ fund Managers due to the nature of some of their mandates.

I thank Murray Weatherston for bringing this discussion to the attention of the CFA Society of New Zealand, which is the local sponsor for GIPS. I'd like to comment on a number of points made so far, as someone who actually knows a thing or two about GIPS.
First, I am surprised (but maybe I should not be) that the ISI is going to tender and only to accounting firms for finding a solution that it knows (or should know) very well already exists: GIPS. I've had numerous discussions with Vance Arkinstall going back more than ten years now on the subject of GIPS and how NZ firms should come into compliance and asking for ISI to assist with that happening. ISI never really had any interest in GIPS it seems.
I also agree with Murray (and others) that that accounting firms are not necessarily the best candidates to assist here.
It is true that GIPS is a set of standards that apply to firms as a whole and not to specific investment products or funds. But it is important to know that a firm has some discretion as to how to define itself for GIPS compliance purposes. There is of course clear guidance provided (this is actually laid out right in the very first provision of the GIPS) on this matter. Simply stated, it does not necessarily have to be the firm as a whole, but can also be a distinct business entity of the firm, should a firm prefer to come into compliance only for a distinct business. KiwiSaver in itself could be construed to be such a distinct business for firms who do provide KiwiSaver solutions.
As for comments made by Dave and Kimble, I can only imagine that they must be accountants to write such nonsense. Maybe they should educate themselves first, before commenting on something they seem to know little about. Good luck, for instance in creating something better or more strict than GIPS. There have only been over 30 countries and 1000s of volunteers behind the development of GIPS over the past 15 years to make it what it is today...
Finally, I agree with Robert Oddy that it's not just for KiwiSaver that something needs to be done. But it seems crazy to me to not at least be prepared to consider how GIPS could apply to KiwiSaver providers.
But of course, I know that New Zealand likes to ignore what the rest of the world does and often seems to prefer looking at things ideologically and as a result enjoys reinventing the wheel all the time. After all, what else is there to do to keep all the accountants busy?
One final point: if the Securities Commission and the Government Actuary are serious in addressing this whole lack of local standards when it comes to reporting past investment performance results to prospective clients, such as for example, in a prospectus or investment statement, then i would like to suggest that they seriously consider either making GIPS compliance mandatory for all KiwiSaver providers by a certain date or actively seek to find out why they are not GIPS compliant.

Louis, I am not in disagreement with you, so should probably clarify what I said above.

GIPS has both requirements AND recommendations. To be GIPS compliant a firm must adhere to the requirements, but not necessarily the recommendations.

One requirement is that all local laws must be followed. If the local laws are more strict (which could mean the local laws follow the recommendations rather than just the requirements), then the local law MUST take precedence. This is the sort of improvment that can be made. And there may well be other things not covered in GIPS yet that would be good also. And there is no reason why they shouldnt be included in the local standards.

Nobody should interpret what I said as meaning that I think GIPS are inappropriate for NZ, or that the requirements arent an improvement on what we have at the moment.

Also I dont think the standards should be set solely by accountants, which is why I also said that the proposed standards should be made public before release to allow outside input.

So presumably Louis you believe it would be more beneficial for a retail investor to be given a composite performance figure representing all of the global equity mandates a house is managing rather than the performance figure for the specific global equity fund that the individual is actually invested in? I think you'll find that retail investors are more interested in how their specific fund is performing rather than the composite performance of the entire global equity desk.

Composites are useful for institutional investors not retail investors.

GIPS is an excellent standard and has been adopted by many global fund houses - however I have never encountered any offering documentation for a Luxembourg UCITS fund (part I of the Lux law of 20 Dec 2002) that contains GIPS references or disclosures. (Lux UCITS are of course the most widely distributed retail mutual funds in the world). The CESR recommendations pertaining to the new UCITS IV rules, specifically the disclosures within the KID (key information document) make no mention of GIPS. CESR has instead recommended a simple, standardised, retail investor friendly disclosure approach to be used in all KIDs which replace simplified prospectuses from July 2011.

Many of the European fund houses who issue UCITS funds will also follow the GIPS standards and will use the GIPS disclosures and templates for institutional/wholesale investors and non-UCITS fund investors, however the pan-European UCITS rules and CESR guidelines supersede the internally adopted GIPS standards.

I believe this approach should be mirrored in NZ. Fund houses should certainly be strongly encouraged to adopt the GIPS standards, but when it comes to the uniform disclosure of fund performance to retail investors I believe NZ should be following the CESR-recommended approach.

Dear Dave and Kimble,
Thanks for your comments.
Of course, GIPS is not the answer to everything. But it offers a possible answer here for the specific matter related to KiwiSaver providers' past performance reporting standards.
What i wrote earlier was that it would seem possible for KiwiSaver providers to define their firm as the KiwiSaver business, for the purposes of claiming compliance with GIPS. In other words, the only funds that would be in the required composites are the very funds on offer for KiwiSavers here in NZ.
Of course, it would be best for a firm to decide to come into compliance for the whole actual firm's offerings, as is preferred under GIPS. But to look at coming into compliance with the best global standard there is, even if only for their KiwiSaver business, would at least be a start in the right direction for the local industry/market. Don't you think?
After all, the GIPS standards are already there and globally accepted. There is no need to reinvent or come up with a new ideological solution for NZ. Nor is it constructive, in my view, to want to address a bigger problem (in other words, the gross lack of compliance industry wide in NZ with any standard) when there seems to be a pressing one to deal with here and which seems to be readily solvable with GIPS: KiwiSaver performance reporting.

Louis, if GIPS is the answer for KiwiSaver, perhaps you could fill-in the gaps in my knowledge and explain exactly how it would work and still be easily understood by the average KiwiSaver investor? We have already established that, in theory, KiwiSaver could be ring-fenced for the purposes of GIPS compliance. We have also established that said funds would be required, under GIPS, to produce composites. The thing that I have trouble with is 1, how would KiwiSaver issuers produce composites given that the majority of KiwiSaver funds are fund-of-funds and invest into a number of underlying wholesale funds run by multiple fund houses domestically and overseas? And 2, once you have the composites (presuming you can calculate them in the first place) how do you explain them to retail investors who just want to know the one year performance for the ABC Conservative Fund they have invested in and aren't at all interested in the one year composite performance of all conservative investments managed by ABC and/or their underlying fund managers?

I'm afraid that I cannot see the benefit of composites to retail investors in KiwiSaver or any other retail fund for that matter. I can definitely see the benefit of composites when looking at a big global fund house with multiple invesment desks each managing multiple funds. That is why composites are there - so that houses cannot cherry pick individual funds based on strong performance and use them to represent the peformance of the entire desk.

I don't think composites would aid KiwiSaver transparency.

I strongly recommend you read the CESR recommendations re UCITS IV published late last year. I believe that UCITS is in fact the global standard for retail mutual funds and CESR has produced a retail-investor friendly standard for the presentation of past performance to retail investors which in my view is the most appropriate not just for KiwiSaver but for all NZ domiciled funds.

I stress that the CESR approach is not competing with GIPS as a global standard for performance measurement, however as a set of regulations it does supesede GIPS for European UCITS funds.

Regulation is key here. The regulators should in my view follow the CESR approach for retail funds and at the same time work with industry to promote the volutary adoption of GIPS.

As an example of the problem I think Dave is talking about, ING manages their own Balanced fund, there is an SIL one, another Aon one, and an AMP one. All of these are KiwiSaver funds, so would be, presumably, all fenced in the same ring.

Also, are NZ managers really in the position to cherry-pick their returns?

I won't pretend to be an expert on KiwiSaver. I've been pleasantly not participating or being involved in the local superannuation industry over the past five years. So I don't know how many of the KiwiSaver providers would have, as it seems ING has, based on Kimble's comment, multiple offerings of the same strategy. But I suspect it's the exception.
In any event, my point is still entirely valid. Let me explain a bit more. First of all, if I'm right that most KiwiSaver providers have only 1 product for each strategy offered, then there is no need to create a ‘complex to explain to retail investors’ composite, as Dave seems to suggest.
Each composite would consist of only 1 fund; hence, the composite would be the fund. And for prospectus of statement purposes, the regulatory requirement could be to present the past performance of each KiwiSaver product in accordance with GIPS, by requiring a disaggregation of the individual products whenever there would be a situation (such with ING, it would seem) where there are more than 1 product in any one composite.
If you look at a sample presentation of the past performance of a GIPS compliant composite, I'm sure you'll agree that the average retail investor would find it easy to understand. It's basically annual returns and annual benchmark returns and size of assets each year, plus disclosures.
As for the argument that if any single KiwiSaver product should also invest in a number of other internally and externally managed products, then that may or may not be GIPS compliant: bollocks, I say. That’s not a correct interpretation of GIPS.
I'm not sure why you are both so intent in pushing some European regulation as opposed to something that is global and developed by the industry (i.e. self regulation), as opposed to a regulator or industry association of investment firms.
Please stop complicating things unnecessarily. Please give GIPS due consideration as a solution.
I'm also not sure either why the ISI seems intent in developing yet another partial standard (covering fees only, it seems and developed I would imagine by the very firms whose performance reporting is at issue here!).

First you say that one good thing about GIPS is that it is developed by the industry (i.e. sel regulation) and then finish by saying that the standards developed locally suffer because they are being developed by the industry. A little inconsistent, dont you think?

On the composites issue, are you saying that all individual funds could be in their own composite? So this would be one GIPS standard that could, in effect, be ignored. Because a composite of a single fund isnt really a composite at all.

Kimble, i don't know who you are, but it would be nice for the record and readers of this blog to know your full name and maybe where you work, because you seem to have an agenda here that's not very GIPS friendly.
As for me, of course i am a strong supporter of GIPS, since I've been part of the governing body of professionals developing it and promoting it for many years around the globe, especially in Asia. I'm also a director of the CFA Society of NZ, which is the local sponsor of GIPS. It is my professional duty to ensure that the integrity of GIPS is maintained in NZ.

Anyway, i did not contradict myself as you suggest. I wrote that GIPS is a GLOBAL industry standard, developed over many years and by many PROFESSIONALS (i.e. INDIVIDUALS and not FIRMS) who are experts in their field, volunteering their time in the best interest of the industry to create what is now recognized GLOBALLY as best practice with respect to presenting and reporting past performance.
Then i wrote that ISI is once again it seems (because i don't know much about it) intent in developing another PARTIAL and LOCAL standard that appears (because again i don't know any more about it than what i read in the paper) to be initiated by members of ISI, which are FIRMS with a commercial interest and so, may or may not be driven by the best interests of the investing public (e.g. compared to their commercial interest) as to the manner in which this new standard will be developed.
As for your last nonsense, i.e. that a single fund cannot also be a composite, well... what can i say?
Are you suggesting that a firm that would have only one fund on offer or one strategy to offer all their clients could not as a result come into compliance with GIPS? How fair would that be?
A composite is defined in GIPS as the 'aggregation of individual portfolios representing a similar investment mandate, objective, or strategy". So if a firm happens to have only one, then the one is the composite as well.

Sorry in advance for the long comment.

Fair enough on the differentiation between firms and individuals in setting an industry standard. That is just something that stood out from what you wrote, but I think your reply explained it.

I dont see how any of what I said could be described as being GIPS unfriendly. My original point, and one I have reiterated, is that GIPS is not the final solution. It shas a lot to offer as a minimum standard, but their adoption shouldn't restrict any possible improvements.

The CFA society itself says that GIPS are a minimum standard, and they further imply this by seperating the minimum requirements from the recommendations. I dont think it is wrong to say GIPS promotes best practice in their recommendations, but it sets the minimum standards in its requirements. Surely there can be only one "best practice" and this cannot be defined by requirements alone.

If you like, you can interpret what I am saying as a call to consider the adoption of the recommendations in addition to the requirements.

I should also point out that I did explicitly write: "Nobody should interpret what I said as meaning that I think GIPS are inappropriate for NZ, or that the requirements arent an improvement on what we have at the moment."

I do not have an "agenda", but even if I did, I dont see how anyone could interpret it as a wholesale rejection of GIPS or anything close to that.

Now, if GIPS requires that all funds be in at least one composite, and all funds in NZ will be seperated into their own composite to accomodate the problem Dave brought up, then the requirement is unnecessary. Right? It is like saying that a golfer has to be part of a team, but a team can be a single golfer.

It is a rule that would no longer have any meaning or pratical purpose. Which means if managers are currently able to cherry pick then they would still be able to.

Of course, if managers arent currently able to cherry pick returns then this wont matter at all.

So, as I asked above, are NZ managers really in the position to cherry-pick their returns?

There is something that hasnt been mentioned here yet, but I think is a particular benefit of adopting GIPS standards in NZ. If GIPS was adopted formally, any future changes to GIPS would have to be adhered to as well. As recommendations become requirements, the standard in NZ would have to improve. This constant improvement can be difficult to foster domestically and I think it is probably impossible to do legislatively.

Thanks Kimble for another glorious contribution to this endless diatribe. (By the way, i still don't know who you are. Come on... be transparent!)

I always thought that for something to improve on what is considered to be the minimum, that something would have to exceed the minimum or have more than the minimum to show for it. Are you suggesting that, for KiwiSaver providers or NZ fund managers, they should be subjected to a greater standard than one they don't already seem to be able or willing to comply with? That's ridiculous! Or maybe you're suggesting a higher minimum ONLY with respect to a specific aspect of the GIPS standards, i.e. how fees are treated or whatever. Well, that would most certainly NOT consist in a higher standard than GIPS, because a firm could then comply with your 'higher' standard and still woefully lack compliance with GIPS in many other respects...

As for your analogy with golf, i really can't follow your logic. GIPS states that for a 'FIRM' to comply with GIPS all of the FIRM's portfolios must be included in at least one composite. But it is possible for a 'FIRM', for the purpose of claiming compliance with GIPS, to be defined as a 'DISTINCT BUSINESS ENTITY' (in accordance with how this expression is defined in GIPS) such that this more limited entity (e.g. KiwiSaver business) may well have only one portfolio qualifying per composite that needs to be created. Of course, the firm would then only be able to claim compliance for its KiwiSaver business AND NOT THE WHOLE FIRM. That goes without saying and is all stated clearly in GIPS.

Finally (I hope...), there is no suggestion whatsoever of cherry picking here. If a firm that provides KiwiSaver products would need to include more than one product in any composite in order for its KiwiSaver business (as a FIRM) to comply with GIPS, then that is just what would need to happen. As i said from the very beginning, i don't know whether or not it would be possible for all KiwiSaver providers in the industry to come into compliance with GIPS (on the basis of the KiwiSaver business only) without having to create any composite with more than one fund/product/portfolio in it. But there is nothing either that stops a FIRM in compliance with GIPS to provide supplemental information. For example, if there happened to be two or three funds/products in one composite, the firm could well provide the numbers for each underlying fund/product as well.