Views on improving the integrity of global capital markets
14 February 2024

Take the SEC Marketing Rule Survey by 1 April  

The CFA Institute United States Investment Performance Committee (USIPC) and the Investment Adviser Association (IAA) have created a joint survey to identify and report on current practices and industry trends for complying with the performance requirements of the SEC Marketing Rule.

Why Are We Conducting This Survey?

We want to be able to answer the often-asked question: What is everyone else doing to comply with the SEC Marketing Rule?

TIle for Global Investment Performance Standards (GIPS)

Who Should Take the Survey?

This survey is for all investment management firms that are subject to the SEC Marketing Rule. Your firm does not have to claim compliance with Global Investment Performance Standards (GIPS®) or be located in the United States to take the survey. If your firm is subject to the SEC Marketing Rule, we want to hear from you!

If you are a service provider, please encourage your clients to take the survey.

Is the Survey Anonymous?

The survey is completely anonymous. Any data will be released only in aggregate form.

How Do I Take the Survey?

Click here to take the survey. We ask that only one person per firm take the survey to avoid duplicative responses.

When Can I Take the Survey?

You can take the survey through 1 April 2024.

How Long Is the Survey?

The survey has 15 questions, and we estimate that it should take no longer than 15 minutes to complete.

What Will I Be Asked?

The survey asks about the following topics:

  • Firm demographics, including assets under management (AUM) and whether the firm claims GIPS compliance
  • Use of actual vs. model fees for net returns
  • Calculations and presentation of returns for prescribed time periods
  • Whether you treat contribution to returns, attribution effects, and yield as performance that must be presented on a net basis
  • Calculation methodologies for investment-level net returns
  • Method of information submission to databases
  • Types of investors that can receive hypothetical performance
  • Biggest challenges for complying with the Marketing Rule
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How Do I Receive the Results? 

We will announce the survey findings in the GIPS Standards Newsletter. You can sign up for the GIPS Standards Newsletter here. IAA Members will be informed about the survey results via e-mail and through the IAA Today newsletter.

Take the joint USIPC-IAA SEC Marketing Rule Survey.

If you liked this post, don’t forget to subscribe to Market Integrity Insights and CFA Institute Research and Policy Center.


All posts are the opinion of the author. As such, they should not be construed as investment advice, nor do the opinions expressed necessarily reflect the views of CFA Institute.

Image credit: ©Getty Images/PeopleImages


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About the Author(s)
Krista Harvey, CFA, CIPM

Krista Harvey, CFA, CIPM, is a director on the Global Industry Standards team at CFA Institute. Previously, she held senior roles on Investment Operations and Performance teams at TIAA, Jennison Associates, and Goldman Sachs. Prior to joining CFA Institute, Harvey was a longtime volunteer. She chaired the United States Investment Performance Committee (USIPC) and was a member of the GIPS Standards Interpretations Subcommittee. Harvey also co-founded and co-chaired the CFA Society of New York Performance & Risk committee. She received a BA in economics from New York University.

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