PE funds have largely avoided adopting CFA Institute’s Global Investment Performance Standards (GIPS), but new guidance issued by FINRA may nudge some funds over the line. FINRA Regulatory Notice 20‑21 (Notice) issued in mid‑2020 states that internal rates of return (IRRs) for unrealized investments in marketing materials used by FINRA members in retail communications to retail investors should be calculated in accordance with GIPS. Broker-dealers that are FINRA members are beginning to require PE funds that use IRRs for unrealized investments to comply with the Notice, typically by asking for a representation of compliance. Fund managers subject to the Notice are not required to become GIPS compliant on a firmwide basis, but they must review their calculation methodologies to ensure consistency with GIPS as to specific funds in question. Some managers are also voluntarily going the extra mile, however, to attain firmwide GIPS compliance. This second article of a two-part series discusses how broker-dealers and fund managers have responded to the Notice; how funds can prepare GIPS‑compliant IRRs; and when funds should consider achieving GIPS compliance firmwide. The first article described the Notice’s expectations and to which funds they apply; the intent and market reaction to the expectations; and the possible implications of non-compliance. See our two-part series on the impact of the SEC’s new marketing rule: “What Constitutes an ‘Advertisement’ and How to Adhere to Principles-Based Standards” (Mar. 23, 2021); and “Disclosures in Non‑Standard Calculations and Requirements When Using Promoters” (Mar. 30, 2021).