RE: November 6, 2007 Memorandum “Frequent Trading”
I have just learned of your intention to impose a restriction on Thrift Savings Plan (TSP) trading activity, specifically limiting participants to no more than two (2) transfers per month. I believe this will have a serious, negative impact on my ability to maximize my retirement account, which in turn lowers my quality of life in retirement. This is incongruent with the philosophy of the TSP program.
As a career federal employee faced with the challenge of ensuring I have put aside adequate funds for my retirement, the TSP is an excellent investment option. Through my active participation, my returns have been much greater than they would have been if the number of transfers was restricted, as you are recommending.
Based on the September 18, 2006 Government Executive article, “Cost of running TSP lower than anticipated”, the September 17, 2007 “Minutes of the Meeting of the Board Members”, the “Federal Retirement Thrift Investment Board Budget”, and numerous other resources, the cost of administering the TSP is and has been under budget, specifically for years 2003, 2004, 2005, 2006, and the increase in 2007 is not entirely due to increased trading costs, but most likely due to “Other contractual services”, and the production of a DVD for participants who don’t read the available material.
As justification for the transfer limitations, you cite Federal Employees' Retirement System Act of 1986 (FERSA) sec. 8475 which directs the board to “develop investment policies…which provide for…low administrative costs.” However, in 5 CFR Ch. VI, Subpart D “Contribution Allocations and Interfund Transfer Requests”, §1601.32(4)(b) “Limit. There is no limit on the number of contribution allocations or interfund transfer requests that may be made by a participant.”
To allow my continued active participation in securing adequate retirement income, I would be more than willing to pay an off-setting fee to TSP for the increased transaction costs. Therefore, I ask that you give further consideration to imposing restrictions on TSP trading activity.