Benchmark Governance Framework
The Scopes Desk
How Scopes administers its rules-based benchmarks and published reference metrics, set out against the four parts of the IOSCO Principles for Financial Benchmarks so a compliance or audit reviewer can map our practice to the principles they already use.
This is a voluntary self-assessment, not an external audit, an assurance engagement, or a claim to be a regulated benchmark. It describes how the rail is governed and points to the live record where each statement can be verified independently, including the one principle that does not apply.
Part A
Governance and oversight
Principle 1 Overall responsibility of the administrator · Principle 2 Oversight of third parties · Principle 3 Conflicts of interest · Principle 4 Control framework · Principle 5 Internal oversight
One named administrator holds responsibility for every published value, and the single most important control is structural: the administrator takes no positions in what it measures.
Administrator
Scopes Reference Data, LLC is the administrator and retains responsibility for the design, calculation, and publication of every benchmark and reference metric, including any component it computes through a third party.
Independence (the core control)
Scopes and its founder take no positions in any market Scopes covers and do not trade its desks. A benchmark administrator that holds positions in what it measures cannot be trusted to calculate the index; the referee is the natural, conflict-free administrator.
Conflicts of interest
Inquiries are logged to a conflicts register; any inquiry from a venue Scopes measures, or an affiliate, is flagged for review before engagement, and a build check bars customer-name claims and client-logo displays until a named client consents in writing.
Internal oversight and control
How the benchmarks are run is itself a governed, append-only record: every methodology version, every pre-registration logged before its outcome is known, and every correction, dated. The oversight record is public, not an internal file.
Part B
Quality of the benchmark
Principle 6 Benchmark design · Principle 7 Data sufficiency · Principle 8 Hierarchy of data inputs · Principle 9 Transparency of determinations · Principle 10 Periodic review
A benchmark is only as good as the record it is calculated over and the ability to prove that record was not altered after the fact.
The record (data sufficiency)
Every tracked market has been recorded since inception, append-only and bitemporal, with book depth. The archive an index is calculated over already exists, rather than beginning the day a mandate is signed.
Hierarchy of inputs
Determinations are anchored to observed venue data (as-of transaction and quote data), with a published liquidity floor: a quote counts only with a bid above 0 and an ask below 100, or non-zero 24-hour volume. Expert judgment is constrained by rules fixed in advance, not applied case by case.
Verifiable integrity
Each UTC day, Scopes computes a Merkle root over that day’s append-only record and anchors it to Bitcoin via OpenTimestamps, mirrored to a public repository. A past value can be proven to have existed on its date and to be unaltered since, without trusting Scopes.
Transparency of determinations
Each covered family is delivered as three series, the market price (as-of), the Scopes Fair Value, and the benchmark, through the point-in-time API and Reference files, so a determination can be reproduced from the inputs.
Part C
Quality of the methodology
Principle 11 Content of the methodology · Principle 12 Changes to the methodology · Principle 13 Transparency of changes · Principle 14 Submitter code of conduct · Principle 15 Internal controls over data collection
Rules are published in advance and versioned; once a value is published under a version, that version is never re-cut.
Published, versioned methodology
Each family’s methodology is published on launch and carries a SAMURAI statement (measurand, universe, construction, and the limits of the measure). It is immutable once published: a change launches as v2 alongside v1, and rules never change retroactively.
Consultation on material change
Material methodology is opened for consultation before it takes effect: the Scopes Calibration Index shipped a v0.9 consultation draft before v1.0 became effective. Material changes carry advance notice (10 business days) before they take effect. Where a version is finalized after some of the outcomes it scores are already known, the affected values are labeled BACKFILL and are never presented as prospective: the index’s first published values are BACKFILL (v1.0 was finalized after that window’s outcomes), and only observations captured and resolved from the effective date forward are LIVE.
Transparency of changes
Every version and every correction is appended and dated in the public Oversight Log, never overwritten, including corrections made before a version takes effect. A reader can see exactly what changed, when, and why.
Submitter code of conduct
Not applicable. Scopes benchmarks are calculated from observed market data, not from a panel of submitters, so there is no submission process to govern. This is stated rather than papered over.
Part D
Accountability
Principle 16 Complaints procedures · Principle 17 Audits · Principle 18 Audit trail · Principle 19 Cooperation with regulatory authorities
The record is built to be audited: an externally-timestamped, append-only trail that a third party can verify independently.
Audit trail
The bitemporal record, the public Oversight Log, and the daily Bitcoin-anchored integrity digest together form a complete, externally-timestamped audit trail. The underlying record is deliverable as Reference files, so a reviewer can reconstruct any published value from the inputs.
Corrections and complaints
Errors are corrected by appending a dated correction, never by overwriting a past value, and corrections are published in the Oversight Log. A data or methodology concern can be raised through the contact channel on Reference; corrections are issued within one business day of confirmation.
Records retention
The archive is append-only since inception: nothing is deleted. Where a past row predates a current rule, it is grandfathered and disclosed rather than backfilled, so the record always reflects what was known at the time.
External audit (stated honestly)
Scopes has not commissioned an external third-party audit or assurance engagement, and these benchmarks are not supervised benchmarks under any benchmark regulation. The cryptographic integrity record is designed to make an independent audit straightforward when a mandate calls for one. We would cooperate with a client’s auditor or a competent regulator.
Where to verify
Every statement above resolves to a page in the live record. Nothing here is a brochure claim; each row is independently checkable.
| Principle area | How Scopes meets it | Verify |
|---|---|---|
| Independence / conflicts | No positions; conflicts register; pre-engagement flagging | /institutions |
| Oversight and change log | Append-only versions, pre-registrations, corrections | /benchmarks/sci/oversight |
| Methodology | Published, versioned, SAMURAI statement, worked example | /benchmarks/sci/methodology |
| Record integrity | Daily Merkle root anchored to Bitcoin; public mirror | /integrity |
| Data inputs and rights | Venue data, liquidity floor, per-venue redistribution rights | /sources |
| Delivery and corrections SLA | Three-series delivery, correction and change-notice windows | /reference |
The fences
- Scopes constructs and administers benchmarks. It does not advise on positions, strategies, or sizing, ever.
- Scopes and its founder do not trade markets covered by its desks.
- Benchmarks are rules-based, specified in advance, and versioned; rules never change retroactively.
- Administration is independent: the client has no discretion over calculation; corrections are appended, never overwritten, and disclosed.
Benchmark Administration · Oversight Log · Reference · Integrity
Published by Scopes Reference Data, LLC. The IOSCO Principles for Financial Benchmarks are the framework this page is organized against; reference to them does not imply endorsement by, or supervision under, IOSCO or any regulator. Research and information only, not investment advice.