What is the difference between a "benchmark" and a "proxy" within the meaning of the Delegated Regulation? If an AIF does not have a sufficient historical price time-series and the PRIIP manufacturer

What is the difference between a "benchmark" and a "proxy" within the meaning of the Delegated Regulation? If an AIF does not have a sufficient historical price time-series and the PRIIP manufacturer therefore calculates the MRM class and/or performance scenarios using the historical prices of a comparable AIF, is the other AIF a benchmark that must be disclosed in the section "What is this product?" of the key information document according to Article 2(2a)(d) of the Delegated Regulation? And in this case, is the past performance of the other AIF to be published on the website of the PRIIP manufacturer pursuant to Annex VIII, Point 11 of the Delegated Regulation? Benchmarks are expected to be indexes, such as of stocks, bonds, interest rates or commodities, that can be used to measure the performance of investment funds. The existence of a benchmark for a particular AIF relates to how the fund is designed and managed, and specifically whether the management of the AIF includes or implies a reference to a benchmark in accordance with Article 2(2a)(d) of the PRIIPs Delegated Regulation. In this case, the benchmark needs to be described in the ‘What is this product?’ section. Additionally, if it is an AIF that is required to publish past performance (point 1(b) of Annex VIII of the PRIIPs Delegated Regulation), this shall also include the past performance of this benchmark in accordance with point 11 of Annex VIII of the PRIIPs Delegated Regulation. Where there are not sufficient historical prices for the AIF itself, but there are sufficient historical prices for this benchmark of the AIF, the benchmark is expected to be appropriate for the purpose of calculating the MRM class and if so, it should be used for the calculation. Similarly, this benchmark should be used for the performance scenario calculations, in accordance with the conditions set out in point 12 of Annex IV of the PRIIPs Delegated Regulation (case 2). However, there might be other cases, where the AIF does not have a benchmark in the sense that Article 2(2a)(d) of the PRIIPs Delegated Regulation does not apply, but where a separate benchmark exists in the market that is reasonable to use to calculate the MRM class or performance scenarios. In this case, the benchmark needs to be appropriate, i.e. representative in accordance with point 7, second subparagraph of Annex II and point 16 of Annex IV of the PRIIPs Delegated Regulation. This includes the requirement that such benchmarks fulfil the necessary criteria regarding the frequency and length of price history, and as such that this price data exists in the market (e.g. it cannot be generated synthetically, such as by using estimations, artificial intelligence-models or algorithms). The other cases include case 3 in Annex IV of the PRIIPs Delegated Regulation, where it can be possible for an AIF to use a benchmark regulated by Regulation (EU) 2016/1011 to calculate performance scenarios. By definition, case 3 does not include benchmarks that need to be referred to in the ‘What is this product?