GIPS Verification

Regarding whether to continue to claim GIPS compliance, the compliance department will _most likely_ respond that:

Incorrect. Independent verification isn't required to continue to claim compliance with GIPS.

Incorrect. Neither the portfolio history nor the compliance status will transfer to Xian Brothers. Portfolio history won't transfer, as the decision-making process isn't independent of the clients. GIPS also don't allow for the transfer of compliance status to a new firm.

That's correct. Requiring trades to be cleared in advance with clients would make this portfolio nondiscretionary, and thus excluded from GIPS compliance.

independent verification is needed.

the portfolio history and compliance status should transfer to Xian Brothers.

the addition of this new portfolio should not change status of Xian Brothers’ GIPS compliance.