Standard III(D): Performance Presentation
When you communicate performance, make reasonable efforts to ensure it is fair, accurate and complete. Do not cherry-pick accounts or periods, label simulated results and prior-firm records clearly, and include terminated accounts. Complying with the Global Investment Performance Standards (GIPS) is the recommended way to meet the Standard.
Before this: Standard III(C): Suitability
On the exam
- Demonstrate the application of the Code of Ethics and Standards of Professional Conduct to situations involving issues of professional integrity
- Recommend practices and procedures designed to prevent violations of the Code of Ethics and Standards of Professional Conduct
- Identify conduct that conforms to the Code and Standards and conduct that violates the Code and Standards
Demonstrate III(D), recommend procedures and identify compliant conduct. Expect cherry-picking, simulated-results and prior-employer items. The usual wrong answers ban simulated results outright, demand full detail in a brief presentation, or blame Standard I(C) or V(C).
How deeply to learn each part
- Know the idea
- Understand it in general. It frames other topics, but you will not calculate with it.
- Use it
- Understand it well enough to solve a question with it. Recognize when it applies.
- Memorize
- Learn it by heart. The exam will not give it to you.
You know this one. The full lesson is folded away. The takeaways, formulas and checkpoint below are your quick refresher, and the checkpoint is a fair test of whether you still do.
You tested strong here. The full lesson is folded away. The takeaways, formulas and checkpoint below are your quick refresher, and the checkpoint is a fair test of whether you still know it.
What does Standard III(D) require?
When you communicate investment performance, you must make reasonable efforts to ensure it is fair, accurate and complete . The point is to give clients and prospects credible information and to stop them being misled about your results or your firm’s.
Memorize
- It covers performance measurement as well as presentation. Any practice that would misrepresent a member’s or firm’s record is caught, whether the figures describe single accounts, composites or groups of accounts.
- It covers past and expected performance. Do not state or imply that clients will earn a return that was earned in the past.
- It is not limited to separate accounts. Pooled-fund figures you take responsibility for must be accurate, and an analyst who promotes the success of past recommendations must also be fair, accurate and complete.
- Avoid Memorize practices that mislead
- Cherry-picking best accounts or best periods only
- Dropping terminated accounts survivors-only record
- Unlabeled simulations model results shown as actual
-
- Disclose Memorize so the audience is not misled
- Simulated or model results say so
- A prior entity's record where and how it was earned
- Gross, net or after-tax which basis applies
-
- Method Use it compliance practices
- GIPS compliance the best method
- Weighted composites of similar portfolios, not one star account
- Keep supporting records the data behind each figure
-
Which practices mislead?
A composite groups similar portfolios so that one weighted figure describes the whole strategy. A record built from the best account, or one that drops terminated accounts , shows only the survivors and overstates what a typical client received. Choosing flattering periods does the same job across time.
Simulated results (model or back-tested returns) are not actual client returns. They may be shown when clearly labeled as simulated and explained. A prior-firm record may be shown if it is clearly identified as the record of a prior entity, and fair, accurate and complete.
A brief presentation , such as a headline return in a talk, is acceptable, but the detailed information behind it must be available on request. Best practice adds a note that the information is limited.
What is the recommended method?
For a manager showing the performance of assets under management, complying with the GIPS standards is the best way to meet III(D), and members should encourage their firms to comply. The GIPS reading itself is in the 2026 curriculum only (see the GIPS lessons, 2026 curriculum). Without GIPS, you can still comply by:
- considering the knowledge and sophistication of the audience;
- presenting the weighted composite of similar portfolios, not a single representative account;
- including terminated accounts, with a clear note of when they ended;
- disclosing what explains the figures: simulated results, a prior entity’s record, and whether returns are gross of fees, net of fees or after tax;
- keeping the data and records behind the numbers.
Where do the lines fall?
| Situation | Verdict |
|---|---|
| A manager advertises the return of her best account as “our equity performance” | Violation |
| Back-tested returns are shown without a hypothetical label | Violation |
| A manager starting a new firm shows his old record, stating clearly where and with which team it was earned | Acceptable if fair, accurate and not misleading |
| A composite leaves out three accounts that closed after poor results | Violation |
| A pitch shows five-year returns and says the full composite presentation is available on request | Acceptable |
Try this 0 of 3
- Rule on all five pitch-book claims right first time
- Pick the fair figure in the best-three case first time
- Clear the conference talk right first time
Case 1 of 3 The pitch book
Harrowgate Capital, a fictional manager, is printing its pitch book. Facts behind the page: its equity composite holds every fee-paying equity account since 2015, including closed ones. Its best single account returned 14.2% last year. Three bond accounts that lost money left in 2022 and were dropped from the bond composite. Its quant strategy went live last year; earlier figures come from a back-test. Its CIO joined in 2024 from Talbot & Rhee with her whole team. Rule on each claim on the page.
Step 1 of 6 Claim 1 of 5
"Equity composite: 7.8% a year over ten years, net of fees. Includes all accounts, open and closed."
Read the case, then answer each step. 3 cases.
Go deeper Why composites stop cherry-picking
If a firm may choose which accounts to show, it will show the best. A composite fixes the rule in advance: every discretionary account following a strategy goes in, including the ones that later close, and the return is a weighted figure for the group. The GIPS standards formalize that discipline, which is why III(D) points to them. How composites are built was part of the 2026 GIPS reading, which the 2027 Level I outline does not include.
Go deeper Gross and net returns
Gross returns exclude management fees and sometimes trading costs, so they always look better than net returns. Neither is wrong, but an unlabeled figure can mislead a client who assumes it is what they would keep. State the basis next to the number, and show net returns where the audience will judge value after fees.
Memorize this
MemorizeStandard III(D): what to know cold
| Topic | The rule |
|---|---|
| Test | Reasonable efforts to make performance fair, accurate and complete |
| Scope | Past performance and reasonably expected performance. Whole firm, one member, written or oral |
| Do not | Cherry-pick accounts or periods; drop terminated accounts; imply past returns will repeat |
| Must label | Simulated or model results; a prior firm's record; gross, net or after-tax basis |
| Brief presentation | Allowed. Supporting detail must be available on request. Best practice notes that it is limited |
| Best method | Comply with the GIPS standards. Otherwise use composites of similar portfolios and keep records |
Memory hook Whole record, honest label: every account, every period, and a tag on anything that is not real, gross or borrowed.
Know it cold Ask three questions of any figure: is it fair, is it accurate, is it complete?
- Avoid Memorize practices that mislead
- Cherry-picking best accounts or best periods only
- Dropping terminated accounts survivors-only record
- Unlabeled simulations model results shown as actual
-
- Disclose Memorize so the audience is not misled
- Simulated or model results say so
- A prior entity's record where and how it was earned
- Gross, net or after-tax which basis applies
-
- Method Use it compliance practices
- GIPS compliance the best method
- Weighted composites of similar portfolios, not one star account
- Keep supporting records the data behind each figure
-
How it is asked
-
Cherry-picked period
Marketing shows only the three years of outperformance and omits weaker five- and ten-year results. Violation?
Yes, III(D). Trap: "the three-year figure is accurate".
-
Back-tested results
A start-up shows model results clearly labeled hypothetical, with the method explained. Violation?
No. Simulated results are allowed when labeled. Trap: "may never be shown".
-
Which action complies?
Which action is most consistent with III(D)?
Include terminated accounts in historical composite performance. Trap: removing accounts closed after poor results.
Exam traps
- Thinking a brief presentation must carry full detail. It need not, if the detail is available on request.
- Thinking simulated results are banned. They are allowed when clearly labeled as simulated.
- Confusing III(D) with I(C) Misrepresentation. III(D) is the specific Standard for performance figures.
- Presenting a single best account as the firm's record, or dropping accounts that left after poor results.
Checkpoint
3 exam-style questions. About 90 seconds each.
1A fund manager's marketing shows only the three-year period in which the strategy outperformed, leaving out the five-year and ten-year results where it lagged. Did the manager violate the Standards?
2A start-up manager shows back-tested results from a quantitative model in a pitch. The results are clearly labeled hypothetical and the method is explained. Did the manager violate the Standards?
3The action most consistent with Standard III(D) is to:
Key takeaways
- Performance must be fair, accurate and complete.
- No cherry-picking accounts or periods. Include terminated accounts. Label simulated results and prior-firm records.
- Complying with the GIPS standards is the recommended way to meet III(D).
All Ethical and Professional Standards formulas, every lesson
Practice exam-style questions on Guidance for Standard III: Duties to Clients
Questions about this lesson?
Where this comes back
- Standard III(E): Preservation of Confidentiality Guidance for Standard III: Duties to Clients
Questions candidates ask
What does Standard III(D) Performance Presentation require?
Make reasonable efforts to ensure that any performance you communicate is fair, accurate and complete. Do not cherry-pick accounts or periods, include terminated accounts, and label simulated results, prior-firm records and the gross or net basis.
Can a manager show performance from a previous employer?
Yes, if the presentation clearly shows that the record belongs to a prior entity, and is fair, accurate and complete. Claiming it as the new firm's own record without that disclosure would mislead.
Can simulated or back-tested results be shown to clients?
Yes, if they are clearly identified as simulated, with enough explanation for the audience to judge them. Presenting them as actual results is a violation.
Spotted an error? Tell us and we will fix it.