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Hi David, have you spent any time reviewing FI360 or CEFEX’s IPS practices and guidelines? In case you aren’t familiar with those organizations, they are marketing themselves as the leaders in the fiduciary standard-setting space. In my limited time helping clients implement those standards, I get the feeling they would find your IPS grossly inadequate. Thoughts?
Jason: Thanks for your comments, which are well taken. “Grossly inadequate” might constitute understatement, as I can’t imagine any such arbiter of best practices in institutional investing deeming my bare bones IPS anything other than scandalous. As with so many aspects of investing, the challenge of fashioning agreement on the essential elements of a well-crafted IPS is rooted partly if not primarily in semantics. By my lights, an investment POLICY statement should be concise enough such that all members of the governing body whose actions it governs (investment committee and/or full board) should be able to recite it more or less from memory. This doesn’t mean that other documents governing deployment of the capital in question shouldn’t be created and put into practice, nor that these other documents must meet the standard of brevity (for IPSs) just suggested. By way of example, permit me to quote JFK in his memorable address to the nation during the Cuban missile crisis: “It shall be the policy of this nation to regard any nuclear missile launched from Cuba against any nation in the Western Hemisphere as an attack by the Soviet Union on the United States, requiring a full retaliatory response upon the Soviet Union.” A pretty concise policy statement, we’d all agree, and an effective one, I’d argue, albeit not one that obviated the need for detailed documentation by qualified personnel within the US military of procedures governing the actual deployment of weaponry if and when the US were to come under attack. Thanks again for weighing in. David