In February 2024, IBM Promontory were engaged to perform a limited assurance review of USD-AXI and USD-FXI’s degree of implementation of certain IOSCO Principles for Financial Benchmarks. IBM Promontory is IBM’s risk management and regulatory compliance consulting arm. IBM Promontory’s review considered the messages and findings from IOSCO in September 2021 and July 2023, as well as consideration of potential “inverted pyramid” risk. As previously confirmed in a public statement, neither USD-AXI or USD-FXI were included in the scope of IOSCO’s July 2023 review. IBM Promontory also completed a follow up to their initial report which focused on recommendations made in their initial report and on Invesco Indexing’s implementation of those recommendations and concluded IOSCO Principles 6, 7, and 9 are fully implemented for USD-AXI and USD-FXI. IBM Promontory’s initial and follow up reports are available here.