FINRA Requires Unrealized Fund IRRs to be Presented in Accordance with the GIPS Standards (Issuers and Fund Managers)

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The FINRA release of Regulatory Notice 20-21 on July 1, 2020 includes clarified guidance for calculating and presenting IRR for use in retail communications by FINRA member firms. The notice allows the use of IRRs for investments or funds that have been fully realized but further requires utilizing the calculation methodologies of the GIPS® standards for investment programs/funds that include both realized and unrealized holdings. Both private placement issuers as well as placement agents that are FINRA members and broker-dealers involved in the creation and distribution of the retail communication should be familiar with the nuances of the notice.

Join ACA for a complimentary webcast discussing the main areas of impact to private placement issuers and fund managers, including:

  • Overview of FINRA Notice 20-21 focusing on IRR guidance
  • Overview of the GIPS standards and options for complying with FINRA Notice 20-21
  • Impact on compliance, finance, and performance departments
  • Peer insights on expected due diligence from broker-dealers

Related Resources

Interested in learning more? Check out our recent blog post FINRA Leverages the GIPS Standards for Standardizing Private Placement Performance Marketing highlighting the impact of Regulatory Notice 20-21 for both issuers and broker-dealers.