Subject: December 26 newsletter from TSPSHAREHOLDER.ORG
From: "TSPShareholder.org"
Date: Wed, 26 Dec 2007 15:18:13 -0500 (EST)
To: newsletter@tspshareholder.org

Money makes the world go 'round   TSPSHAREHOLDER.ORG
 
Vol 1.  No. 5                                                                                       December 26, 2007
SO EXACTLY HOW MUCH WILL THE PROPOSED TRADING RESTRICTIONS SAVE?
 

Taking away freedom always has a price.

 

And, according to the Thrift Board, stopping people from controlling their own money is their idea of providing for the greater good of the 3.8 million TSP participants. 

 

But we question that. We only have to look at November 2007, to see that the impact of restricting people from controlling their own money would have devastating impacts. 

 

 

NOVEMBER RATES OF RETURN:
 
      C Fund                     S Fund                             I Fund
                      (- 4.20%)                 (-5.65%)                           (-3.72%)
 

For the month, those who were actively monitoring their own investments were able to move quickly to the sidelines, and escape the downward plunge of the markets. The Board recommends holding on and losing money. We advocate that an educated TSP Shareholder is in the best position to monitor and move his or her own assets.

 

To put things into perspective, TSP Chief Investment Officer  Tracey Ray has advised the TSP Thrift Board that moving money means there is some kind of a financial emergency, because some employees desire to move their money more frequently than she believes is necessary. We believe that is just her opinion, and we disagree.

 
Her predecessors spent millions of dollars to enable TSP Shareholders to have a daily access to their accounts.  But that was before Ms. Ray came along. Her background is in the "buy and hold" tradition.  There's nothing wrong with that, but she doesn't seem to  understand the importance of allowing individual freedom in one's own risk management style. "Buy and Hold" is ONE theroy of how to invest one's money. There are other theories and investment styles as well. Dollar cost averaging, or swing trading, are both investment styles that the millions spent by TSP Shareholders a few years ago bought the capability to exercise. We bought it.  We paid for it. And now Ms. Ray says we have to give up our investment. She wants to limit the freedom to pursue individual investments options, to go back to a limited number per month restriction. She says that will save shareholers money.  

 

But she hasn't said how much such a restriction would save the TSP shareholders. That is an important question that hasn't been answered.  How much will the vast majority of TSP's 3.8 Million shareholders "save" by invoking draconian trade limits? 

 

 And who exactly does the Thrift Board think are being harmed by continuing to have the ability to control one's own money?

 

 First, it's NOT those who sit in the "G" fund with all their retirement cash. The "G" fund now represents some 33% of the total assets in the TSP, at $76,758,000 dollars as of the end of September, 2007.  If someone is a pure "G" funder, they gain nothing at all from the proposed imposition of trading limits.

 

And it isn't holders or traders of the "C" fund, as C fund holders now represent 34% of all TSP assets, and trading costs in the C fund are less than 1 basis point, or 10 cents for every $1,000 invested.  Those who hold the C fund aren't making any gain by limiting trades.  Maybe a dollar a year, if that.

 

Could it be the L funders who are "harmed"?  Some 500,000 employees now place their funds in the L funds.  That's a very wise choice for many people.  Those who cannot or will not learn how to make a better return on their own invest in the L funds.  We support that. But if a typical L funder (L2020 is the largest holdings at 39% of FERS employees holding shares of the L2020) only has a small percentage of his/her account invested in the I fund, which is the fund being cited by Ms. Ray for high costs.

 

By the way, the L2020 only has 18.1% of it's assets in shares of the I fund as of September 2007. Which means, on an average $70,000 L2020 account balance, means only $12670 is exposed to the I fund.  It also means, that if you left the money alone, as Ray and the Thrift Board suggest, you would have lost -2.33% of you money in November alone. That is a loss of $1633 dollars in November if you simply "bought and held".

 

Would limiting trades save money?  We don't know for sure. Tracey Ray has not made a public estimate of how much of that 6 basis points she thinks will be saved by limiting trades.  How much? She won't say. She thinks it will save money. 

 

 We're not so sure.

 

 Since she won't put a figure on any estimated "savings" by limiting trades, We'll have to make up a figure, just for demonstration purposes. Let's say it's 3 basis points for the year, rather than the 6 basis points that the I fund now costs.  We believe the savings won't exist, but just for the sake of argument, let's say it saves 3 basis points in a year on the I fund. That works out to just 1/4th of one basis point per month.

 
That's .000025 percent.
 
On $12,670 exposure to the I fund, that means "trade limits" COULD save a whopping .31 cents for the month.

 

That same "L funder" person, by not being able to trade, would have "saved" about 31 cents.   And lost a fixed amount of $1632.70 in November, by not moving to safety.

 

But if they had "managed their own money", and bought L2020 on November 1, sold on November 6, bought on November 19th, and held till the end of the month, they would have made  $2,009.59 in profit.   On just three trades in a month. Three is above the limit that the TSP Board is proposing.  

 

Is it worth saving 31 cents, to give up the ability to make $2,009.59?  

 

It is, under Tracey Ray's math.

 

She says restricting the ability of a person to control their own money and saving 31 cents is more important than allowing a person the right to control their own destiny.

 

While it is true that not everyone can pick the highs and the lows of the market, anyone who manages their own money can make an educated guess of the direction of the market's travel.  And can judge their own level of risk and reward, to determine if they want to be in the markets, or out.  We're adults, not children. Our actions are not "harming" anyone.  The cost of doing business is minimal. And it's important to a lot of people to maintain freedom in our democracy.

 
We believe in education.  We believe in the importance of sharing knowledge with our fellow employees, about how they can take control of their own futures, and make their money work for them. We educate by sharing ideas in places like http://tsptalk.com and  http://finance.groups.yahoo.com/group/TSP_Strategy/ .
We believe it's better to teach a person about finance, than to let them suffer in the dark.
 

 

And we believe Tracey Ray, and the Thrift Board, are missing the big picture.  It's not THEIR money at risk.  They need to stop frightening TSP shareholders by claiming that the costs to their accounts are being damaged. It's simply not true. It's not hurt any of the "G" funders at all. And it's cost less than $4 per year per person overall to maintain freedom, less than the costs of compiling, printing, and sending out yearly statements to members.

 

Remember, for a $70,000 L-2020 account holder in November, limits MAY have saved  him perhaps .31 cents

 

And cost them the freedom and opportunity to gain $2,009.  

31 cents

 

Freedom in America is important. 

 
Especially to the 3.8 million Federal Employees and U.S. Military service members who invest in the TSP, and are the share holders.
 

TSP Thrift Board needs to understand that.

 
Are imposed trading limits Penny wise?  Or Dollar foolish?  
 
You decide.
 

 
Thrift Board, please check:
Vanguard doesn't limit Index ETF moves!

 

Recently, TSP Thrift Board employee Tracey Ray told a radio audience on Federal Radio (a Washington D.C. area radio station), that she advised the Thrift Board to impose limits on trading because it would be "Like all other mutual funds".

To begin with, the TSP funds are NOT mutual funds. Mutual funds have a fund manager, who picks and chooses which stocks to hold.
 
The TSP is a passive managed investment, meaning that the stocks are composed of entire indexes, more like "Exchange Traded Funds", or ETF index funds in the private sector.
 
During that interview, Ms. Ray said that most mutual funds charge fees to prevent people from trading. She cites the Vanguard funds, some of the largest funds in the nation for retirement IRA and 401(k) plans, as limiting trades by mandating a 60-day period between moving money.
 
 
 
In fact, in that radio interview, Ms. Ray seems to think that the most important reason to stop people from controlling their own money, is that "it is pretty much impossible to time the market".  They looked at imposing fees, but they can't figure out how much to charge.  But they have to protect people from themselves.
 
And, besides, according to Ms. Ray, all the big mutual funds prohibit trades. In the interview, Ray said: "Vanguard, one of the largest funds in the country, makes every participants wait sixty days before they can repurchase a fund after selling it".
 
 We call this into question. 
 
Vanguard does have some 60 day limits. But they are only on actively managed mutual funds, not Index ETFs. And, within Vanguard, with more than 120 different fund choices,  you COULD move your money every day for 60 days, and not have buy the exact same fund back twice.
 
While it is true that a few of Vanguard's funds impose redemption fees, the fact is that only 24 of Vanguard's 120 funds impose any kind of redemption fee.  And Vanguard does NOT limit index Exchange Traded Funds (ETF's) within a 401(k) account.
 
Vanguard does NOT limit trades or impose fees on ETF Index funds, including Foreign Index ETF's. ETF's are very much similar to index funds. 
 
The difference is with Vanguard ETF's, you can buy and sell in the same day, if you wish.  TSP requires that buy orders be placed before noon, for execution overnight. Vanguard charges a small fee for the transaction, TSP currently charges nothing.  And Vanguard funds average 11 to 21 basis points, rolled into the yearly return, as the cost of having the ability to trade in or out in a single day.  TSP, by virtue of it's massive size, has reduced costs for all shareholders to just 8 basis points in the "I" fund, and 2 basis points for all it's funds overall.  Two basis points is just 20 cents for each $1,000 invested.
 
Vanguard's policies:

Vanguard has about 120 funds to choose from, and only 24 of them have any kind of redemption fees or fees if you sell early. Some, as noted above, require a redemption fee if you hold it less than 60 days. the redemption fee is either .25%, 1% , or, in the case of about 5 foreign funds, 2%.

However, for the other 90+ funds, there is no fee.
------------------------------------------------------------------

Here is their policy on trading retirement accounts at Vanguard: As you can see, it DOES NOT apply to ETF funds- those which try to mimic indexes.

Here is the link to the list of ETFs that Vanguard allows unlimited free trading in 401(k) style plans:
 
__________________________________________________ ________

Frequent-trading policy

If you sell or exchange shares of a Vanguard fund, you will not be permitted to buy or exchange back into the same fund, in the same account, within 60 calendar days. However, this rule does not apply to:
  • Vanguard money market and short-term bond funds.
  • Vanguard ETF™ Shares.
 
Check it out for yourself at:
 
Vanguard's list of U.S. Stock index ETFs which can be traded without
restriction in a 401(k) :
++++++++++++++++++++++++++++++
STOCK INDEX ETF Funds:
ETF share class  Fund (Trading symbol) Target index
 
Vanguard
Total Stock Vanguard Total Stock MSCI
® US Broad
Market Index Fund Market ETF (VTI) Market Index
 

Vanguard Extended Vanguard Extended S&P Completion
Market Index Fund Market ETF (VXF) Index
 
Vanguard
Large-Cap Vanguard Large-Cap MSCI US Prime
Index Fund ETF (VV) Market 750 Index
 
Vanguard
Mid-Cap Vanguard Mid-Cap MSCI US Mid
Value Index Fund Value ETF (VOE) Cap Value Index
 
Vanguard
Mid-Cap Vanguard Mid-Cap MSCI US Mid
Index Fund ETF (VO) Cap 450 Index
 
Vanguard
Mid-Cap Vanguard Mid-Cap MSCI US Mid
Growth Index Fund Growth ETF (VOT) Cap Growth Index
 
Vanguard
Small-Cap Vanguard Small-Cap MSCI US Small
Index Fund ETF (VB) Cap 1750 Index
 
Vanguard
Value Vanguard Value MSCI US Prime
Index Fund ETF (VTV) Market Value Index
 
Vanguard
Small-Cap Vanguard Small-Cap MSCI US Small
Value Index Fund Value ETF (VBR) Cap Value Index
 
Vanguard
Growth Vanguard Growth MSCI US Prime
Index Fund ETF (VUG) Market Growth Index
 
Vanguard
Small-Cap Vanguard Small-Cap MSCI US Small
Growth Index Fund Growth ETF (VBK) Cap Growth Index
 
Vanguard
Dividend Vanguard Dividend Dividend Achievers
 
Appreciation Appreciation Select Index*Index Fund ETF (VIG)
 

Vanguard High Vanguard High FTSE
® High Dividend Yield Index Fund ETF (VYM) Index
 
For a complete list of fees and expenses of the Vanguard funds, see:
 
 
WHAT PEOPLE ARE SAYING!
Here are some extracts from some of the 2,500 people who have already signed the petition to STOP TSP TRADE LIMITS found at http://tspshareholder.org
 

Dec 20, 2007,Peggy Leaf , Colorado  Stop TSP TRADE LIMITS!

please let me control my own financial future! Thank you

 

Dec 20, 2007,EUGENE OBRIEN , California Stop TSP TRADE LIMITS! 

 HOW ABOUT LETTING US VOTE ON YOUR PROPOSAL?

 

Dec 20, 2007, Richard Crusan , Florida Stop TSP TRADE LIMITS! 

Limit should not have been imposed without first going to shareholders within TSP. This a democratic society not an authoritarian one or dictatorship!

 

Dec 20, 2007,Mike Lucas , Pennsylvania   Stop TSP TRADE LIMITS!

Thank you for your concern, but I already have a mommy

 

 

Dec 20, 2007,Gretchen Anderson , Virginia  Stop TSP TRADE LIMITS!

The Government decided my retirement would be a "three-legged stool" of Social Security, federal retirement, and TSP. The Goverment therefore effectively forced me to risk my retirement savings in the Market by making 1/3 of it market-sensitive. I need the flexibility of limitless trading to maximize my returns and minimize my risk--because the Government is not providing my retirement as it did for employees under CSRS.

 

 

Dec 20, 2007,Eric Young , Maryland  Stop TSP TRADE LIMITS!

Dear Sir or Madam, As an investor in the Federal Thrift Savings Plan TSP, I believe I should have the ability to make at least a once daily transfer among the funds in the plan, as I presently can. Indeed each transaction should be executed immediately for each account, instead of having to place an order by 11 am Central Time and waiting until 3pm for execution. The funds in the TSP are based on ETF%u2019s (Exchange Traded Funds) that are traded constantly. In 1987 the Dow went down 23% in one day!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! Please do not place any new, tighter limits on transactions. Sincerely, Eric W. Young

 

Dec 20, 2007,Laszlo Braun , New Mexico   Stop TSP TRADE LIMITS!

Limiting us would hurt our ability to define our financial future as we see fit. Please don't do that! Laszlo

 

 

Dec 20, 2007,Meyer Persow , Delaware   Stop TSP TRADE LIMITS!

Leave our TSP money alone.

 

Dec 20, 2007,ERNESTO GRANILLO , Virginia   Stop TSP TRADE LIMITS!

I tried trading but it was a pain. However, TSP should not impose it's will or point of view without consulting the people whose money is being invested. If fees are too much work to manage maybe we need other people to manage our TSP. If people are willing to pay a fee I say let them!!!

 

 

Dec 20, 2007,Duane Jackson , Georgia   Stop TSP TRADE LIMITS!

Leave MY money alone. Let Freedom Ring!

 

 

 

Dec 20, 2007,Diane F Smith , Maryland   Stop TSP TRADE LIMITS!

I'm outraged at the proposal to limit the number of trades per month to 2. I believe this is an investment program & not a bank savings account. No one can tell me how to make money in my TSP account. That's my decision if I make 10 trades a week. It appears that no many current or retired Feds are aware of this proposed change outside of Washington, DC & informing them is critical. TSP members also need to know the "real" reason costs are increasing as you have so adequately pointed out on your web page. It's not the more frequent trades as indicated in the 12/20/07b Washington Post Newspaper. As a recent retiree, if the TSP Board enacts this measure, I'm prepared to roll my money over to another IRA in the private sector. This measure is discriminatory because it takes away the ability to make money as the stock market changes based on economic & political news. In fact, I recommend that stock fund changes made via internet occur faster than overnight. With the computer, changes need to be made instantaneously instead of having to wait overnight. I'm happy to work for the defeat of the TSP Board proposal.

 

 

Dec 20, 2007,John Johnson , Georgia   Stop TSP TRADE LIMITS!

Many never change their fund designation, ever. For those who care and know the risks it is their retirement. Let choice be free and often!

 

 

Dec 20, 2007,Sheila Clay , Illinois   Stop TSP TRADE LIMITS!

Reverse the Decision to Limit TSP Interfund Transfers! It should be FREEDOM of CHOICE!

 

 

Dec 20, 2007,Anonymous , Virginia   Stop TSP TRADE LIMITS!

The tsp used to restrict movement between funds to monthly because of software limitations. Now some Nazi control freak wants to restrict my movement of my tsp funds (all of ours) again. This is unfair. While I probably won't move my funds more than twice a month, I want to keep the freedom to do so. If there is a minimal transaction cost, spread it out amongst the fund costs.

 

 

Dec 20, 2007,Anonymous , Maryland   Stop TSP TRADE LIMITS!

Don't change TSP.

 

 

Dec 20, 2007,Alexander Smith , California  Stop TSP TRADE LIMITS!

There is a bias against active traders, who have been labeled "day traders," which is of course impossible. Does the board assume all TSP participants are financially incapable of managing their funds? In this era of subprime, it is clear more folks should be actively managing and trading to be accountable for their own futures.

 

Dec 20, 2007,JACQUELINE Bowman , Washington D.C.   Stop TSP TRADE LIMITS!

Let me judge when to move my money and not the TSP Board.

 

 

Dec 20, 2007,Michael Hoge, Washington D.C. Stop TSP TRADE LIMITS!

It is our money and we live in a democratic, capitalistic society where we pay for what we get. If one wants to leave there money stagnant where it is, that is their choice. If one wants to "play" with their money as much as they would like, that too is their choice. Like E-trade, each person should pay small transaction fees and that would be the solution. If the contractor that operates the transfers cannot handle the workload, then we need a new contractor and the TSP advisory council should recompete the work so that we can have a free-market capital based system where one is allowed to do as they please with their money. God Bless the USA!

 

 

Dec 20, 2007,Anonymous, California Stop TSP TRADE LIMITS!

The TSP board should be required to communicate proposed changes directly to participants. I would have no idea this was happening if not for GovExec.com. Clearly there is a problem but the proposed solutions are the easy solution for the board, not in the best interests of participants. I would like the board to put a little more effort into this one. It really makes you wonder whether the entire effort should be turned over to a large mutual fund company.

 

 

Dec 20, 2007,Brenda D. Bennett, Maryland Stop TSP TRADE LIMITS!

One of the aspects that attractive me to the TSP was the fact that I had control of my investments daily. This, change is has taken this control from me, and I believe will affect my life savings.

 

 

Dec 20, 2007,J K, Virginia Stop TSP TRADE LIMITS!

It appears we are heading back to the days of transfers being effective at the end of the month. This only maximizes losses and decreases gains in markets such as what we are experiencing now. The buy and hold philosophy doesn't work well for my situation and my account balance reflects it. Managing MY money as I see fit regardless of cost to me or to a fund in general is a fact of life. All mutual funds have costs...that is just the way it is. Let us manage our money and the board has no business dictating how I choose to invest.

 

 

Dec 20, 2007,Gilberto Gonzalez, New Jersey

 

Stop TSP TRADE LIMITS!
I don't  appreciate when someone else takes control of my own funds. These are my money and I would like to make my own decision without anyone telling me what I should or should not do with it.

 

 

Dec 20, 2007,Stephen Andersson, Illinois Stop TSP TRADE LIMITS!

I am very upset by the move by the TSP to limit our trades. This severely limits an informed person's ability to build his/her nestegg, and the change has been made with little justification. Even a small charge per transfer would be preferable to the TSP's current proposal.

 

 

To read more comments from TSP SHAREHOLDERS, please visit the on-line petition at http://tspshareholder.org and see for yourself what other TSP Shareholders are saying.
It took seven years, and $350 million dollars to allow TSP Partcipants to be able to control their own future with daily access to their money.
 
Employees finally could control our own money when the new system started in June, 2003. 
 
It worked.
 
Exactly AS DESIGNED.  
 
The NOW, the Thrift Board is proposing to wipe it all away in a single stroke of the pen.
 

TSP Goes retro.....

Remember when?

Flashback.....June 16, 2003, the TSP goes LIVE with their daily trading plan.....as reported in Govexec.com



+++++++++++++++++++++++++++++++++++

House committee to investigate TSP system
By Tanya N. Ballard
tballard@govexec.com
July 17, 2003


The House Government Reform Committee will review customer service problems associated with the Thrift Savings Plan's new automated record keeping system at a July 24 hearing, a committee spokesman said Thursday.

Six years in the making, the new automated record keeping system was finally
launched on June 16 only to encounter Web site problems. While TSP officials tried to fix the problems, they advised participants to access the system by telephone, but the subsequent barrage of calls to the system prevented some participants from getting through. The delays increased the frustration many participants had harbored over the years of delays and the millions of dollars spent building, then launching the system.

"People are very upset and we understand why," TSP spokesman Tom Trabucco said Thursday. "We know we have a problem with the phones and we are working on that."

Under the new system, federal workers should be able to make daily changes to their Thrift Savings Plan investments, a significant change from the monthly upgrades provided under the old system. The 3 million TSP account holders should also be able to access their account balance updates each day, transfer money from one fund to another, change the amount of their monthly payouts after they retire and make a partial withdrawal of money, rather than a full withdrawal, as soon as they retire. Another feature of the new system allows participants to submit loan applications electronically, though there is still a paper-based step for married Federal Employees Retirement System (FERS) members, according to Trabucco.

"The TSP new system may be up and running, however it is near impossible to reach anyone by phone or complete the application electronically as was promised and advertised as a special new feature," a federal employee recently wrote to GovExec.com. "It's one thing to say the system is working. It's quite another to say so when it is patently not true. In fact, saying the TSP is working is like [President] Clinton saying he didn't inhale or have an affair with [Monica] Lewinsky. It may be true, but only if words are redefined."

During the past month, many GovExec.com readers have complained that their loan applications seem to be in limbo, interfund transfers have not been completed, and attempts to contact someone for help have been futile.

According to Trabucco, 106,641 interfund transfers were processed and 12,120 loans were issued as of July 15, but a data entry backlog has created some problems.

"We do have a backlog of data entry work and that includes loan repayment checks, paper loan applications and paper withdrawal applications, but we've brought more resources to bear on this and are working through it," Trabucco said. "What we are trying to do is work through, in particular, this data entry issue and get those moving through. We think that things will be improving when that's done."

Trabucco also noted that the Web site is handling as many as 50,000 transactions an hour, with the highest volume of Web site hits occurring between 8 a.m. and 12 p.m. EST.

The board hired American Management Systems in 1997 to modernize the computer system and give federal employees more tools to manage their 401k-style retirement accounts. The $30 million project was supposed to be completed by May 2000, but when the implementation date was moved back four times and the budget tripled, the board fired AMS in July 2001. The board sued the Fairfax, Va.-based company for $350 million in damages and AMS filed a breach of contract suit against the board. Recently the two
brokered a settlement in which TSP participants will pay $36 million for the failed contract, along with the more than $33 million paid to the contractor who took over the project after AMS was fired.

.
+++++++++++++++++++++++++++++++++++++++++++++
 
Perhaps it's time for the House Committee to investigate again, why the Thrift Board would even consider tossing aside a $350 million dollar investment that works just fine, exactly as intended, and going back to the OLD way of doing business.  

  

The Thrift Investment Board plans to curtail Interfund Transfers, but the proposed solution may cost more than the current problem they are trying to solve. 

 

Better Alternatives Exist.

 

 The Thrift Savings plan is the current retirement fund for approximately 3.8 million federal employees, and U.S. service members.  As of September, 2007, the plan contains over $230 billion dollars, spread out over 5 investment vehicles. 

 

The G fund contains government securities.  The F fund contains bonds.  Three stock funds make up the rest. Two are domestic index funds, reflecting the S&P 500, and a small to mid-cap index fund. One fund, the "I" fund, currently holds approximately $23 billion dollars in foreign securities. 

 

In 2004, the plan was changed.  Prior to that date, the plan only allowed changes in funds once per month.  Under the new system, daily reallocations are possible. While the vast majority of share holders don't move or reallocate their own funds, many shareholders watch the markets carefully, and place their own money where they think it will work for their particular situation best.

 

Legacy Timing Issue:

 

One issue cited by Tracey Ray is that the I fund trades foreign securities. These securities are traded around the world, at times when the U.S. Domestic market is closed.  The TSP established a cut-off time for announcing the day's value of the fund, as of 4 p.m. each day. TSP then made public the closing share prices at 7 p.m.each evening on it's dial in telephone line. TSP originally chose this time, because that is after the U.S. New York Stock Exchanged closed. Until 1996, the C fund, representing the S&P 500, was the only stock fund available to share holders.  

 

When the international "I" fund was added in 1996, the thrift board continued to use the 4 p.m. eastern time cutoff for the day, and continued to announce a daily value of the funds, including the I fund, at approximately 7 PM. eastern time each night. However, the actual value of the shares would not be known until after trading began in overseas markets during the night.  Each day the agent for TSP would make an estimate, called a "Fair Value" estimate, to estimate what the shares would be worth the next morning.  If, during overnight trading, the estimate was wrong, then the error was absorbed as a cost to all TSP shareholders. These costs over time amounted to roughly 8 basis points per year of operation between 1996, when the I fund became available, and 2004, when the trading system was changed.

 

This legacy timing issue means that the market differences between the time of the declared price value by the TSP, and the actual trades conducted later that night,  could either benefit, or hinder, the costs of the associated TSP account holders.  

 

This legacy timing "Fair Valuation" can either help TSP accounts overall, or hurt TSP accounts overall, depending on the day of the trade. The Board has been well aware of this fact for some time.

 

It the  February 20 , 2007  Federal Retirement Thrift Investment Board meeting minutes, TSP CIO Tracey Ray noted that the Fair Valuation of the I fund benefited investors in January, 2007.  The February meeting minutes record : Ms. Ray noted that the I Fund outperformed the index by 62 basis points due to a fair valuation adjustment.

 

In real dollars, that means the trading in the I fund in January 2007 resulted in a profit to the TSP of approximately $20 million dollars for TSP shareholders.  In February, the difference was reversed, the Fair Value method missing slightly, costing 61 basis points, or $20 million dollars back due to the fund manger's Fair Value misestimates.  The net result over the two month period was a net gain for I fund holders of 1 basis point, or about even.

 

In a single day, March 5th, the miss-guess of the Fair Value allowed TSP shareholders a single day gain of $8 million dollars, when traders placed sell orders, the Fair Value was set, and the share prices announced at 7 PM., yet the overseas markets were actually higher when the trades were executed overnight.  The Thrift Board's minutes of April 16th, 2007 note  that Ms. Ray said "it could have easily gone the other way".

 

On November 19, 2007, in a Board Meeting the Thrift Board decided to stop trading of TSP accounts of active members.  Citing a cost of trading on this "Fair Value" issue,  Tracey Ray accused TSP account holders of costing the fund money. 

 

The fact is that some months the trades cost money, and some months they bring in millions in extra income.  In September, 2007, trading resulted in $1.3 Million in PROFIT for the TSP overall. It's not a loss, it's a gain.

 

The fact is that it is the "Fair Value" system of declaring a share price BEFORE the trade is executed that resulted in value errors and potential trading expenses. Sometimes they go in favor of the TSP, and sometimes they don't. Trading restrictions will have little or no affect on the Fair Value errors.

 

This decision to limit trades puts the board in the position of deciding, instead of share holder members deciding, what is best for them. 

 

Shareholders overwhelmingly view this as a wrong decision. According to a Federaltimes.com poll, only 11% of federal employees said they support the decision to limit trades.

 

The solution chosen by the board could increase, rather than decrease, costs for TSP shareholders.  Under the Board's November 19 solution, TSP shareholders will be limited to two trades per month.  This COULD mean that all trades are executed in a single session, rather than spread out over 10 trading days.  For example, two weeks worth of trades COULD be pent up into a single day, and without changing the time the Share Prices are calculated, this could mean the FV problem is actually magnified by a multiple of 10.

 

Federal Employees reject this proposed solution of limiting trades by an overwhelming majority. According to a Federaltimes.com poll conducted over the weekend of November 23rd to 25, only 10% of shareholders thought limiting trading to twice per month was a satisfactory solution to the problem. An overwhelming 83% of shareholders wanted to continue the ability to make daily allocations without restriction, or with a small fee.

 

Federal Times Poll, as of November 2007

Should the Thrift Savings Plan limit the number of fund transfers investors can make?

Yes, to 2 per month as planned. 10 % (399)
Yes, but more than 2 per month should be allowed. 7 % (305)
No, but those transferring money should pay fees to cover transfer costs. 20 % (798)
No, unlimited free transfers should continue. 63 % (2,570)
Total votes: 4072

 

  

 BETTER SOLUTIONS:

 

The only way to eliminate the risk of Fair Value Price errors, is to eliminate or greatly reduce the use of Fair Value pricing. While the SEC guidelines talk about using Fair Value Pricing, the TSP is not subject to SEC regulation. Further, the SEC also allows waivers for alternate plans that more accurately reflect share holder value in the private sector.  The Thrift Board should explore this option.

 

Instead of limiting trades to two per month, the Thrift Board could adopt a policy of not setting share prices until the following morning, once all trading has taken place.  Instead of publishing share prices at 7 p.m. eastern time each evening, the Board easily could wait until foreign markets open, and the trades are executed.  Publishing the share price at 7 a.m. the following morning would allow the elimination of "Fair Value Pricing" guesses, and use the actual price data from trades conducted in foreign markets overnight.

 

Further, it would still allow enough time to update employee account records, and for employees to know their actual account balances within two or three hours of the new set pricing time, in time to decide what to do before the next day's noon cut-off time for making a move.

 

By adopting this change in share price announcement timing, the TSP could eliminate all costs associated with the "Fair Value Price" estimates.  Using the Thrift Board's own figures, this would save TSP account holders over $25 million in administrative costs currently borne by all account holders.

 

Recommendation 1:   That the Federal Retirement Thrift Investment Board retract it's proposed 2-per month limit on TSP trades, and instead adopt a policy to price shares at 7 a.m. each morning, for the shares traded the previous day.  This is a change from the current policy of publishing prices at 7 p.m. each trading day.  A simple 12 hour delay in publishing share prices could save millions in costs to shareholders.

 

This simple change would allow massive savings to shareholders, allow maximum flexibility to shareholders for managing their own accounts, and solve the "Fair Value" swing issue perceived by the Board.

 
Alternate Recommendation 2:  That the Thrift Board adopt a fee of $10 per move to compensate for costs associated with Interfund Moves.
 
Data over the last two years shows, on average, TSP Shareholders make between 180,000 and 220,000 Interfund Transfers per month.  By applying a simple $10 per move fee, fees would generate approximately $24 million dollars per year, more than the TSP currently says that fund moves cost. 
 
The plan would work because A.  It's simple to impose. A minimal amount of software modifications would be required. B. Those who move more often would pay more.  If someone does not move at all, they pay nothing. If someone moves often, they pay for each move. The amount recoups the costs now being incurred, and does it in a simple fashion.
 

Alternate Recommendation 3: Limit the dollar amount of each move to a fixed $200,000 limit per day.

 
The Thrift Board Spokesmen all speak about the daily variations in the amount being trading as one of the items they are concerned with.  Setting a fixed number of trades at two per month does nothing to limit the potential dollar value that could be expected to be traded on any single day. Dollar cost averagers, who currently may take 20% of their account off the table and into safety during strong moves up would be limited if the two trade limit is imposed. But by limiting the dollar amount per day, instead of the number of days per month, the daily variation is reduced, without harming smaller accounts. Large Account holders can still move significant amounts of cash, but the impact of the 300 large dollar traders would be reduced significantly on any given day.
 
 
These are just some of the ideas we think are worth exploring, before imposing draconian limits.  We're talking about other ideas here, and in the http://tsptalk.com message boards, among other places.  If you have ideas on better alternatives, drop by the message boards at TSP Talk and contribute your ideas.
 
We all work better, when we work together.
 
 
See you over at the message boards.

HOW MUCH TRADING IS TAKING PLACE?
 

Amount of I fund traded on any given dayOver the course of a month, an average of about 200,000 Interfund Transfers are made by TSP Share Holders. 

 

The Thrift Board is now saying that they want to limit your ability to move your own money, because too much money is being moved around.

It turns out that they are mostly concerned with moves in the I fund.  So how much money is actually in the I fund?   In September, it was $25,281,000,000
 
And how much was moved on an average day? 
 
Would you believe LESS THAN 1%?
 
That's right.  They want to take away your right to control your own money, because less than $244,000,000, or less than 1%, is being moved on an average day.
 
We believe there are better ways.  Don't let them take away your right to move your money where YOU think it will work for you best.

Sign the petition to STOP THE TSP TRADE LIMITS.

It's at:  http://tspshareholder.org