Wilshire Questions
1. Does CLO have any liquidity restrictions? Other than the 60% equity exposure, are there
other constraints that limit exposure to higher-return assets? Are there any specific
constraints that prohibit the investment committee from investing in private markets?
What
led
to
the
current
investment
constraints?
Response: CLO staff regularly monitors cash flows to ensure sufficient liquidity is
maintained to meet operating needs and investment objectives. From a policy
standpoint, the primary structural constraint is a statutory maximum of 60% invested
in equity securities, with a corresponding minimum of 40% in non-equity investments.
Beyond this, there are no additional hard limits designed specifically to restrict
exposure to higher-return assets. Private investments are permitted, provided they
comply with applicable statutory requirements and are evaluated in light of factors such
as liquidity, investment term, and the source of funds. The current investment
constraints are driven by Oklahoma constitutional and statutory requirements, which
establish the framework within which the Committee and staff operate.
2. What is the reason the incumbent reports on gross of fee returns within performance
reports?
Response: The Investment Plan requires managers to report gross-of-fee returns to
ensure consistent and comparable evaluation against benchmarks at the manager level,
while overall fund performance and objectives are assessed net of fees elsewhere in the
Plan.
3. Is this RFP solely being issued for traditional assets advisory services, or for the entire
investment program (i.e. including private markets and alternatives)?
Response: The Investment Plan outlines two consultant roles—one for marketable
(traditional) securities and one for private and alternative investments—and this RFP is
intended to cover advisory services for the full investment program, including both
traditional assets and private/alternative strategies, consistent with the structure
described in the Plan.
4. When was the last time the Committee reviewed its asset allocation? Could you share the
most recent asset allocation review and the underlying assumptions? Can you share the
rationale behind the seemingly new target allocation to private equity and the Committee
intends this to be implemented (ex: program of direct GP commitments)?
wilshire.com | T +1 310 451 3051 | 1299 Ocean Ave, Ste 600, Santa Monica, CA 90401 USA
Response: The Committee conducts a formal asset allocation study at least every two
years, with interim evaluations performed annually, and monitors the allocation on an
ongoing basis throughout the year. The current target allocation includes private
investments at approximately 1% in the near term and 3% over the long term. This
reflects a measured, incremental approach to building exposure while maintaining
flexibility and liquidity within the overall portfolio. Private investments may be
implemented through external managers or manager-led opportunities, subject to
appropriate approvals. The intent under the Investment Plan is for private markets
exposure to remain modest and thoughtfully integrated into the broader portfolio,
rather than developed as a large, standalone program of direct GP commitments.
Please refer to the following for additional detail on asset allocation study and final
approved monthly performance report:
https://clo.ok.gov/wp-content/uploads/2025-12-31-CLO-Monthly-Report-Final.pdf
https://clo.ok.gov/wp-content/uploads/Asset-Allocation.pdf
5. Are there any particular reasons for the substantial allocation to preferred securities?
Response: The allocation to preferred securities is intended to support CLO’s objective
of providing current income to beneficiaries while still allowing for moderate long-term
growth; preferred investments align well with these income-focused goals and are
subject to explicit quality limits in the Investment Plan, including a cap of 30% of a
manager’s portfolio rated below investment grade at the time of purchase.
6. We noticed there is a 5% allocation to internal real estate. Are there any custom risk and
return assumptions used here, or does the CLO use RVK’s standard core real estate return
and risk expectations?
Response: The Investment Plan permits real property investments of up to 5% of total
assets and establishes a Plan-specific net performance objective requiring returns to
meet or exceed the most recent five-year average return of the Permanent Fund
(excluding real property); accordingly, risk and return expectations for internal real
estate are defined by the Plan itself rather than based on an external consultant’s
standard assumptions. The internal real estate portfolio is treated as a separate asset
class outside of the asset allocation for financial securities, and the Plan allows for either
an internal or external real estate investment consultant. CLO currently utilizes an
internal consultant for this function, and performance monitoring of internal real estate
is outside the required scope of the financial securities consultant. While RVK has
requested information to assist in benchmarking and performance review to support
the real estate consultant—which is appreciated—such involvement is not required
under the current structure.
wilshire.com | T +1 310 451 3051 | 1299 Ocean Ave, Ste 600, Santa Monica, CA 90401 USA
7. For every asset class, CLO’s investment plan lists a target net alpha expectation of 25 basis
points. Does the CLO view every part of the portfolio as equally efficient/inefficient? If not,
why are the alpha assumptions uniform across the portfolio?
Response: The Investment Plan establishes a uniform relative performance objective of
exceeding relevant allocation indices by 25 basis points net of fees over a market cycle
as a consistent governance and monitoring standard across the portfolio; this uniform
hurdle is not intended to suggest that all markets are equally efficient, but rather to
apply a common policy benchmark across asset classes.
8. What is the current manager fee of the portfolio – is it close to the 0.5% limit? Does the
0.5% manager fee target impact the CLO's decisions around active vs. passive management
and traditional vs. alternative investments?
Response: For fiscal year 2025, total investment manager fees were approximately $7.3
million. As of June 30, 2025, total investments were approximately $2.89 billion, so
current manager fees are well below the Investment Plan’s aggregate cap, which limits
total payments to the custodial bank and investment managers to no more than 0.5%
of market value as of the prior June 30. While the Plan does not dictate how the fee cap
should influence decisions between active and passive strategies or traditional and
alternative investments, the 0.5% limit serves as an overall cost discipline and is
considered as part of broader portfolio construction and governance decisions.
9. Aside from good governance practice, are there other reasons for holding this RFP? Are
there current investment issues or pain points with the incumbent provider that the CLO
would like to improve upon?
Response: The issuance of this RFP is driven by the Investment Plan’s requirement to
periodically review consultant services at least every five years, and it is not being
issued in response to specific investment issues or performance concerns with the
incumbent provider.
10.To what extent do internal team bandwidth in handling paperwork impede the CLO from
considering a greater allocation to private markets?
Response: Any potential expansion of private market exposure, including
considerations related to internal staffing capacity and administrative workload, would
ultimately need to be evaluated and discussed with the Commissioners within the
framework established by the Investment Plan.
11. Is there any internal expense levy? If so, could you share what it is?
Response: The Investment Plan does not identify a general internal expense levy;
instead, it specifies approved funding sources for expenses, including realized
investment gains and, beginning July 1, 2026, rental income for real estate investments.
wilshire.com | T +1 310 451 3051 | 1299 Ocean Ave, Ste 600, Santa Monica, CA 90401 USA
12. Is the CLO looking for a consultant who can help with the valuation / due diligence work
of investible opportunities in Oklahoma?
Response: Yes, the Investment Plan contemplates that consultants will support
analysis, due diligence, recommendations, and ongoing monitoring for both marketable
and private investments, including opportunities aligned with the Invest in Oklahoma
Act, consistent with the Plan’s guidelines and statutory requirements.
wilshire.com | T +1 310 451 3051 | 1299 Ocean Ave, Ste 600, Santa Monica, CA 90401 USA
This is the opportunity summary page. It provides an overview of this opportunity and a preview of the attached documentation.