Put two discretionary factsheets side by side. Both say Balanced. One reports 24 months, gross of the annual management charge, from a model portfolio. The other reports five discrete twelve-month periods, net of all charges, from a composite of live client accounts. Both numbers are honest. Neither can be compared with the other, and an investment committee that puts them in the same column has produced a document that looks like due diligence and functions as decoration.
DFM performance comparison is the part of manager selection that advisers most often get wrong, precisely because it looks like the easy part. The numbers arrive pre-formatted. The work is establishing whether they describe the same thing.
The headline number is a marketing artefact
Strategy names in UK discretionary management are unregulated. Balanced at one firm can carry a materially different equity weighting to Balanced at another, and neither is misrepresenting anything. Before a single return is compared, the risk mandate has to be matched on substance: strategic equity range, permitted use of alternatives, currency hedging policy and the volatility band the manager actually targets.
The same applies to the vehicle. A model portfolio return is a theoretical construct showing what the strategy would have delivered to an account invested at inception, rebalanced on schedule, with no cash drag and no client-specific constraint. Real accounts have all three. The gap between the model and the client experience is not a rounding error, and it widens in bespoke services where individual constraints are the point.
Four variables to normalise before you compare anything
| Variable | The trap | What to ask for |
|---|---|---|
| Time period | Since-inception or cherry-picked windows that start after a drawdown | Discrete twelve-month periods, at least five, same start and end dates across providers |
| Fee basis | Gross of AMC, or net of AMC but gross of underlying OCFs, platform and custody | Net of all charges the client bears, with the deducted components itemised |
| Risk mandate | Identical labels, different equity ranges | Strategic asset allocation ranges and realised volatility, not the label |
| Population | A model, or a hand-picked representative account | A composite covering every portfolio managed to that mandate |
Normalise those four and the comparison starts to mean something. Skip any one of them and the exercise is presentational.
Composites are the question that separates the serious
The single most useful question in a DFM performance comparison is this: does this number come from a composite, and what was excluded from it?
A composite groups every discretionary portfolio a firm runs to a given strategy and reports them as one asset-weighted return. It exists to stop a manager choosing which client to show you. The Global Investment Performance Standards set out how composites should be constructed, requiring firms that claim compliance to include every discretionary fee-paying portfolio in at least one composite and to present a defined minimum history rather than a period of their choosing.
Compliance is voluntary and a great many capable UK discretionary managers do not claim it. The absence of a GIPS claim is not a red flag. What is a red flag is a firm that cannot explain, in writing, how its published figures were built. Three follow-up questions do most of the work.
- Which portfolios were excluded from this composite, and on what stated policy?
- Are terminated accounts included for the periods they were managed, or dropped on exit?
- Has any third party verified the calculation, and can we see that verification?
A firm that answers all three in a week is telling you about its operational infrastructure. So is one that sends a marketing deck instead.
What each layer strips away
Structural diagram, not scaled data. The width of each band is illustrative only. The point is that most published DFM comparisons stop at the first or second row while the client lives on the last one, and for portfolios held largely outside wrappers the final step can be the largest single deduction. The wrapper-level detail sits in our guide to the tax implications of DFM portfolios for UK HNW clients, and the cost layers in DFM charges explained.
Return without risk context is half a number
Two managers delivering the same five-year return, one with a maximum drawdown twice the other’s, have not performed equally. For most private clients the second one has performed better, because the client who lived through the deeper drawdown was more likely to leave at the bottom.
The measures worth requesting are unglamorous and consistently informative: realised volatility over the same discrete periods, maximum drawdown and the time taken to recover from it, and capture ratios in rising and falling markets. Downside capture in particular tells you whether a defensive mandate was defensive when it counted, which is a question a five-year annualised figure cannot answer.
Peer context helps here, and UK advisers commonly use the Asset Risk Consultants private client indices as a reference for discretionary outcomes across risk bands. Treat any peer universe as directional. Constituent firms self-select, methodologies differ, and a quartile ranking is a conversation starter rather than a conclusion.
Dispersion is the number almost nobody publishes
Ask a bespoke provider for the range of client outcomes within a single strategy over the last three years, from best to worst, and watch what happens.
A firm with tight dispersion is running a genuinely centralised process with disciplined implementation. Wide dispersion means the result depended on which manager was assigned to the client and when they invested, which makes the composite average a poor guide to what your particular client should expect. Neither answer is automatically disqualifying. A provider that has never calculated it, and cannot produce it, has told you something about its investment governance that no factsheet will.
This is also the question that distinguishes a bespoke service from a model in expensive packaging. Near-zero dispersion in a service charging bespoke fees is worth investigating, a point covered in model portfolio services vs bespoke portfolios.
Hold providers to the standard the rules already set
The FCA’s rules on past performance in COBS 4.6 exist for retail communications, but they make a serviceable minimum standard for anything a provider hands an adviser. They require past performance information to cover complete twelve-month periods, to identify the reference period and the source of the data, to avoid presenting past performance as the most prominent feature of the communication, and to carry a prominent warning that the figures refer to the past.
Use it as a filter. A performance pack that presents an eye-catching cumulative number without discrete periods, without a stated source, and without a defined universe is not the beginning of a comparison. It is a reason to go back and ask for the pack again.
A comparison your file can survive on
Selection decisions get reviewed. The reviewer, whether that is your compliance function, an acquirer’s diligence team or a supervisor, will not be assessing whether you picked the manager with the highest return. They will be assessing whether the comparison behind the choice was reasoned and reconstructable.
That means the file records the basis, not just the outcome:
- The discrete periods used, identical across every provider assessed.
- The fee basis, stated explicitly, with the deducted components listed.
- The risk mandate evidence, showing that the strategies compared were genuinely comparable.
- The population behind each number, composite or otherwise, with exclusions noted.
- The risk measures considered alongside return.
- The reasoning, including why a provider with weaker headline numbers was or was not preferred.
The last point is the one most often missing and the one that carries the most weight. A committee that selected the second-best performer for articulated reasons has evidenced a process. A committee that selected the best performer with no recorded reasoning has evidenced a spreadsheet.
The mechanics of running that process, from charter to minutes, are set out in how to run an investment committee in a UK advice firm. The broader provider assessment sits in due diligence when choosing a discretionary fund manager, and the periodic review obligation once a manager is appointed is covered in ongoing DFM oversight.
The bottom line
Most DFM performance comparisons fail before the analysis starts, because the numbers being compared were never describing the same thing. Fix the inputs first: same periods, same fee basis, same risk mandate, same portfolio population. Then ask the two questions providers rarely volunteer, about composite construction and client dispersion. What survives that process is a short list built on evidence, and a file that explains itself two years later when nobody remembers the meeting.
If you are reassessing your discretionary panel this year, the practical starting point is to request identical discrete-period, net-of-all-cost data from every incumbent and challenger at the same time. The variation in what comes back, and how quickly, is itself a finding.
Frequently Asked Questions
How do you compare DFM performance between providers?
Only after normalising four variables: the time period, the fee basis, the risk mandate and the portfolio population behind the number. A gross-of-fee model return over a three-year period is not comparable with a net-of-fee composite over five years, even if both strategies are labelled Balanced. Ask every shortlisted provider for the same discrete twelve-month periods, on the same fee basis, for the same risk band, sourced from a composite rather than a representative account.
What is a performance composite and why does it matter?
A composite is a grouping of every portfolio a firm manages to a given strategy and mandate, reported as a single asset-weighted return. It matters because it removes the manager's ability to select a flattering example. A firm that can only show a model portfolio return, or a single representative client, is showing you what the strategy was designed to do rather than what its clients actually received.
Are UK DFMs required to publish GIPS compliant performance?
No. Compliance with the Global Investment Performance Standards is voluntary and many UK discretionary managers do not claim it. That does not disqualify a provider, but it does shift the burden onto the adviser to ask how the reported figures were constructed, which portfolios were included and excluded, and who verified them.
What is dispersion and why should advisers ask about it?
Dispersion measures how widely individual client outcomes within the same strategy vary around the composite average. A bespoke service with tight dispersion is running a disciplined process; wide dispersion means the outcome depended heavily on which manager was assigned and when the client invested. Very few providers publish it, and asking for it is one of the fastest ways to test how well a firm knows its own book.
How should performance analysis be documented for Consumer Duty purposes?
Record the comparison basis, not just the conclusion. A file that states which periods were used, which fee basis applied, what the peer or benchmark reference was, and why the committee reached its decision demonstrates a reasoned process. A file containing only a table of returns and a selection decision demonstrates very little, because the comparison itself cannot be reconstructed.