This whole benchmarking against the S&P500 is a little nuts. I would argue that someone who can't beat that index can actually be a great manager and even deserve his fees in any of these cases
-If his drawdowns are significantly limited compared to the S&P500 and he still makes a nice return over the risk-free rate. If he tends to lose 10-15% in bad years, that's pretty good compared to the 30-50% of the S&P. A guy who compounds 6%-7% net a year with max 15% drawdowns will look pretty bad when benchmarked against the S&P500, yet I would argue he is a good manager who is doing good to his clients even though he doesn't beat the market
-If he has some personality or communication characteristic that helps his investors 'stay the course' even during bad times. This enables investors to achive returns above the risk free rate for the long-term, something they would be unlikely to do if they pilled in with 100% of their money on SPY. If they did that, they could be all selling at the lows in a panic. But with the manager, they might just stay the course. Specially if the manager is in communication regularly with investors. That's why I wouldn't knock on Whitney Tilson even though I don't think he can beat the market