Ando Kenichi, a portfolio manager for a Japanese small cap fund at Sakura Investment Company in Tokyo. His benchmark for performance of 2021 is the top quartile of fund managers who manage funds in Tokyo in 2021. In other words, the performance of Sakura for 2021 will be evaluated based on the average performance of the top quartile of fund managers in January 2022, the earliest. Evaluate and discuss whether Mr. Ando has (or has not) a valid benchmark according to the properties identified by Richards (2001).