The provision of accurate and reliable indexes requires the provider to have in place robust governance procedures including an effective oversight framework and well-defined organizational policies. Suitable arrangements for the oversight framework were advocated in the IOSCO Report on the Principles for Financial Benchmarks published in 2013.
For certain uses of benchmarks in the European Union, the making available of certain policy, governance and other index documentation were made requirements in the EU Benchmark Regulation which became effective in January 2018 (EU BMR) and subsequently the UK Benchmark Regulation which became effective in December 2020 (UK BMR).
To fulfil its regulatory responsibilities, the documents that together describe the Wilshire Indexes governance arrangements are published below.
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To ensure that the benchmarks administered by Wilshire Indexes meet the highest standards of accuracy and reliability, Wilshire Indexes has developed a governance framework to oversee all aspects of the determination and dissemination of its benchmarks. The various bodies involved in the oversight of benchmarks administered by Wilshire Indexes are summarised in the Wilshire Indexes Governance Framework Overview. Together, these bodies are responsible for the development and/or approval of the various policies and procedures that apply to the Wilshire Indexes business.
Wilshire Indexes has adopted a Code of Ethics which covers, amongst other things, provisions regarding the management of conflicts of interest including rules concerning personal dealing, and the acceptance and provision of gifts and entertainment.
Queries and Complaints Policy
The Queries and Complaints Policy sets out the procedures to be followed should an index user or other stakeholder wish to query the determination of an index. If the query is not answered to the complainant's satisfaction, the query can be elevated to a complaint for formal consideration by the Wilshire Indexes Executive Committee.
Benchmark Approval, Change and Cessation Policy
The Benchmark Approval, Change and Cessation Policy sets out the procedures to be followed by Wilshire Indexes when approving a new benchmark methodology, changing an existing benchmark methodology (material and non-material changes are distinguished), and ceasing the calculation and publication of an existing benchmark.
The Wilshire Indexes Oversight Function has developed and approved index-specific policies that apply to certain aspects of the administration of Wilshire Indexes benchmarks. These policies supplement the methodology documentation for individual indexes and should be read in conjunction with those methodology documents.
Equity Index Calculation and Corporate Action Guide
The Equity Index Calculation and Corporate Action Guide sets out the method of index calculation including the treatment of corporate actions. The guide also summarises the procedures to be followed in those circumstances where prices for individual securities or securities traded on a particular market are unavailable..
Error Correction Policy for Equity Indexes
The Error Correction Policy for Equity Indexes sets out the procedures to be followed in the event of an error being discovered that affects the calculation of an index.
Input Data Used in Equity Benchmarks
The Input Data Used in Equity Benchmarks document describes the various types of input data that are used in the determination of Wilshire Indexes equity benchmarks.
Policy for the Exercise of Expert judgement
The Wilshire Indexes methodology documents and the index policies published here are written to be transparent and objective so as to minimise the need for expert judgement in so far as is practical. However, there may be circumstances in which expert judgement is required, including in the determination of an input data variable, or in the most suitable implementation of a corporate action, or market event. See Wilshire Indexes Policy for the Exercise of Expert Judgement.
UK and EU BMR
Wilshire OpCo UK Limited is authorised as a Benchmark Administrator and regulated by the United Kingdom Financial Conduct Authority and is listed on the FCA Benchmarks Register.
The EU BMR and UK BMR require authorised and registered administrators to comply with certain obligations set out in the regulations, including making available the administrator's governance arrangements, index methodology documentation and the index policies to be followed in specified circumstances. The EU BMR and UK BMR also require the publication of a Benchmark Statement for each benchmark or family of benchmarks that summarises the essential features of the benchmark methodology and the administrator’s governance arrangements. Wilshire Indexes’ benchmark statements for those indexes being made available for use as a benchmark are published below..