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I highlighted in bold what I consider to be minimal additions and/or grammar changes below:
I highlighted in bold what I consider to be minimal additions and/or grammar changes below:
Here is a draft I plan to send out in the morning. Please tell me what you think I need to improve it as well as grammar, punctuation, and the whole nine yards. TIA
The FRTIB is planning to impose interfund transfer restrictions without consent from the participants or the ETAC. These restrictions are in opposition of the Code of Federal Regulation guide lines. They are listed at the end of this brief. As my advocate I want the FRTIB to rescind their decision to impose limits on TSP trades, including the decision to send threatening letters to selected TSP members.
Market impact and fair valuation are the underlying problems caused by the contractual requirement of BGI, Barclay Global Investment, by TSP. That requirement is to settle our trades by the end of each trading day and that it be reflected in the share price even though the standard for the market is that it takes 3 days to settle trades.
I can only assume that the “trading cost” referenced in each FRTIB meeting minutes attachments are caused by these unrealistic contractual requirements and mass flight to safety during very volatile months.
For example, trading cost of the I Fund Jan. to Sept. 2007 is $12,240,419. One month stands out, August with $10,522,348 or 32.7 basis point in trading cost. Other months that stand out are February and April with $4,198,802 or 24.3 basis points and $1,489,043 or 11.8 basis points, respectively.
August as a whole was a very volatile month and I would venture to guess that more than just the “3000 frequent traders” made interfund transfers that month. More like a flight to safety after the negative sub prime mortgage news started to come out.
The last week in February was also very volatile, erasing all gains for the entire month in a few days. April would seem to be an anomaly at this point as it was not as volatile as the other two months.
The two most volatile months had the largest “trading cost” and they exceed the YTD total. That would tell me that much more than the “3000” were trading those months and the fact is that the policies and contract for clearing our trades through BGI need to be address more than the number of interfund transfers done by a fraction of participants.
Large moves when the market is volatile causes BGI to delay complete payment of those large trades. This is diluting the fund return also, so it is not JUST frequent trading of the I fund, but the shell game that BGI has to play by buying futures contracts because the contractual requirements to settle IFT daily even thought they are restricted to a 3 day settlement period.
There are a number of solutions to solve these problems:
1. Use indicies or ETF’s that follow TSP fund exactly so that they easier to trade on the open market.
2. Stop fair valuation by posting share prices the morning of the following day.
3. Limit trade in the I Fund only using the 3 day rule for trades to settle.
1. TITLE 5--ADMINISTRATIVE PERSONNEL CHAPTER VI--FEDERAL RETIREMENT THRIFT INVESTMENT BOARD PART 1601_PARTICIPANTS' CHOICES OF TSP FUNDS--Table of Contents Subpart D_Contribution Allocations and Interfund Transfer Requests Sec. 1601.32 Timing and posting dates.
(b) Limit. There is no limit on the number of contribution allocations or interfund transfer requests that may be made by a participant.
2. TITLE 5--ADMINISTRATIVE PERSONNEL CHAPTER VI--FEDERAL RETIREMENT THRIFT INVESTMENT BOARD PART 1601_PARTICIPANTS' CHOICES OF TSP FUNDS--Table of Contents Subpart C_Redistributing Participants' Existing Account Balances (Interfund Transfers) Sec. 1601.22 Methods of requesting an interfund transfer.
(a) Participants may make an interfund transfer using the TSP Web site or the ThriftLine, or by completing and filing the appropriate paper TSP form with the TSP record keeper in accordance with the form's instructions. The following rules apply to an interfund transfer request: