There are many ways to manipulate performance presentation in public markets. And both non-discretionary investment consultants and OCIOs are highly creative in manifesting "phantom alpha." Many use strawman benchmarks for individual managers. But the real magic happens when creating portfolio benchmarks of their own design. In my due diligence work for plan sponsors of their consultants/OCIOs, I have seen mis-weighted total plan benchmarks, strawman asset classes, and some go back in time re-weighting benchmarks. And with 20/20 hindsight, they always go in the "favorable" direction.