Of late, my colleagues and I have been involved in numerous conversations on the subject of benchmarks; in fact, I'm about to conduct a focused study for a client on their benchmark construction policies and procedures.
I conducted a GIPS(R) (Global Investment Performance Standards) verification for a firm who occasionally uses benchmarks solely for "reference" purposes; this is quite common with hedge funds, that are "absolute" strategies, where no appropriate benchmark exists. And so, an index like the S&P 500 might be used.
If we look at the definition of "benchmark" in the Standards' glossary we find:
At first blush, one would be inclined to believe that such a benchmark is sufficient, and fulfills the requirements of the Standards. Sadly, this definition is incomplete and therefore misleading, thus the confusion that can arise.
Within the corpus of the Standards we find:
THIS, to me, is a much better definition. Hopefully, in the 2020 or 2025 version, we'll see an expansion of it in the glossary.
And so, if the benchmark is solely for reference purposes, although it fulfills the definition, it fails to meet the requirements of this provision (i.e., I.5.A.1.e.), and the firm must include a disclosure, as required by:
and the "reference" benchmark should be flagged as "supplemental information."