Under what conditions can a performance record be 'ported' to a new firm?

Question

AcadiFi · Accepted Answer

GIPS permits portability of performance records to a new firm ONLY when specific conditions are met, ensuring the transferred track record genuinely reflects the capabilities now in place at the new firm. All conditions must be satisfied simultaneously.

**GIPS Portability Conditions:**

1. **Substantially all investment decision-makers** are employed by the new firm (performance team moves together — not just one portfolio manager)
2. **Decision-making process** remains substantially unchanged and independent — the new firm must support the same investment approach
3. **New firm has records** documenting and supporting the historical performance
4. There is **no break** in the track record (performance continuous)

**If ALL four conditions met:** The historical track record may be linked to the new firm's returns going forward, and presented as the firm's own track record on a GIPS-compliant basis.

**If conditions NOT all met:** Historical record can be shown as 'supplemental information' labeled clearly, but not as the firm's GIPS track record.

Example: In January 2026, a 4-person emerging markets equity team led by portfolio manager Kassandra Meridianos leaves Ashgate Capital to join boutique Thornberry Investments. They bring:
- All 4 senior investment professionals (PM, analyst, trader, risk)
- Same research process, universe, and portfolio construction methodology
- Complete trade records and performance attribution data back to strategy inception (2018)
- Client authorization to transfer accounts with no gap

All four conditions met → Thornberry can claim GIPS-compliant track record from 2018 for its new 'Thornberry Emerging Markets' composite, disclosing team portability.

```mermaid
flowchart TD
  A[Team moves firm] --> B{All decision-makers?}
  B -->|No| C[Not portable]
  B -->|Yes| D{Process unchanged?}
  D -->|No| C
  D -->|Yes| E{Records available?}
  E -->|No| C
  E -->|Yes| F{No break in record?}
  F -->|No| C
  F -->|Yes| G[Portable to new firm]
```

Disclosure required: the new firm must disclose the portability event, effective date, and prior firm affiliation in the composite presentation for a reasonable period.

Under what conditions can a performance record be 'ported' to a new firm?

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