TSP investors suspending contributions

[Show-me]

You all worry too much, the FRTIB, Greg Long, and Tracy Ray will provide all the guidance you need when they think you need it. Empty your minds and think of other things like butterflies and luxurious retirement destinations. They are looking out for us all and will protect us all from ourselves by limiting the number of evil interfund transfers so that you, like the other 99.99% of the sheep will be protected in a extremely lucrative buy and hold strategy.:worried:

Don't ya feel all warm and fuzzy knowing they are on our side and doing what is best for us.

Thanks FRTIB and you TSP.gov geniuses!

 

[XL-entLady]

Good one, Show-Me!

Lady

 

[OBGibby]

Lady -

I'm not knocking active traders (whether TSP or elsewhere), but for my retirement goals, coupled with my knowledge of the markets and investing, I am satistified with the TSP and I anticipate continuing to use it as a vehicle towards partial fulfillment of my retirement goals. But hey, different strokes for different folks.

I suspect most TSP participants, as well as most 401K and IRA participants in the private sector, subscribe to the buy and hold strategy for one simple reason: they don't have the time to become well versed enough in investing to actively trade, and actively trade profitably.

I've worked for three different federal agencies - and all three have been hands-off about TSP participation, contribution amounts and allocations. All have uniformly been insistent in advising their employees of the importance of TSP as it relates to FERS, but the onus has always been placed on the individual employee to decide what fits best for their respective retirement goals. As far as knowledge of the TSP by my colleagues, nearly all have been active in learning about the TSP and using it in their overall retirement goals. One agency even provided an eight hour retirement seminar (run by an outside contractor) to all new employees on day one in order to encourage the new employees to lay the foundation for their retirements as early as possible. I understand that this type of proactive HR effort is not the norm, but not every federal agency or every federal employee is being hoodwinked by their HR or by TSP in general.

I think the problem with federal employees not leveraging TSP (and a proper definition of that is in the eye of the beholder) is not a result of TSP education (or lack thereof), or HR managers pushing certain funds, or whatever - and it's not confined to federal employees only - is that most people aren't thinking that far ahead to prepare themselves for the reality of retirement, whether their public or private sector. Let's face it, we live in an instant gratification society, more concerned with what I can get now, rather than be concerned with the consequences of my short-term actions might have on my long-term.

 

[XL-entLady]

OBGibby, your opinions are well-presented. My cranky responses are probably brought on partly by my current bout with whooping cough. But they are also partly a result of my concern that I had to take a medical retirement in 2008 and the TSP rules may not enable me to make my account last the many years that it will have to.

For example, we just had a significant bear market rally. I was able to catch about 2% gain from that rally. But if I had been able to make unlimited IFTs in real market time I would have made changes that would have netted me a 10% gain. (I don't know why I track that stuff. It makes me nuts. And driving me nuts is a short trip these days.)

Anyway, that is the basis of my frustration, and also the reason why I will be changing my account to an IRA as soon as the market stabilizes to a point where I dare leave "full faith and credit" backing.

Lady

 

[OBGibby]

Lady -

I hope the difficult times you're currently experiencing are soon taken over by better ones. Even though the IFT issue and active trading don't figure prominently in my retirement goals (as of right now), I do appreciate the frustration you and the other proponents of unlimited IFT's feel over the recent decision to limit the IFT's. There should have been more of a lead time given before enactment, and some provision should have been made to allow TSP participants to shift their money to non-TSP accounts, if they so desired, without penalty as a result of the changes.

Get well soon!

 

[Spaf]

Speaking as a member.

There is a matter of contention.

It deals with CRS vs FERS and Management vs Employees. Some may even want to add the Union in on this one!

Members, especially those in FERS should not be satisfied with TSP. By limiting Inter Fund Transfers they have abridged your right to manage your account, in short; discrimination.

To clarify. In day trading no security is held overnight, and impossable to do with TSP. Swing traders hold positions for days or weeks. Position traders for weeks, months, years or more.

The concept of buying and holding forever died after the stock crash of 2000. While some investors may use a buy and hold strategy they look much more critically at what they are holding and are more likely to change their holdings. Hence the position trader, holding for weeks, months and maybe a year or more depending on trends in the economy, the market, and individual funds. The L-Funds of TSP can some what be thought of as position trades as one goes through the years to retirement.

The reason TSP members may not be versed in investing, is flately an omission by management to afford the necessary skills. Education in investing should begin the first year of employment, with annual updates thereafter. Remember, TSP is no longer a "savings" program once out of the G-Fund. However, management will provide for TSP investing education, once it becomes "important" to them. TSP is an option to many in management, remember they are mostly under CRS, not FERS. They do not have to manage investments in completing their retirement goals.

 

[XL-entLady]

Amen, Spaf, amen!

They didn't just change the rules of the game on us. The IFT limit changed the whole game for a swing trader. We thought we were playing chess and ended up playing checkers.

Lady

 

[OBGibby]

Speaking as a member.

There is a matter of contention.

It deals with CRS vs FERS and Management vs Employees. Some may even want to add the Union in on this one!

Members, especially those in FERS should not be satisfied with TSP. By limiting Inter Fund Transfers they have abridged your right to manage your account, in short; discrimination.

To clarify. In day trading no security is held overnight, and impossable to do with TSP. Swing traders hold positions for days or weeks. Position traders for weeks, months, years or more.

The concept of buying and holding forever died after the stock crash of 2000. While some investors may use a buy and hold strategy they look much more critically at what they are holding and are more likely to change their holdings. Hence the position trader, holding for weeks, months and maybe a year or more depending on trends in the economy, the market, and individual funds. The L-Funds of TSP can some what be thought of as position trades as one goes through the years to retirement.

The reason TSP members may not be versed in investing, is flately an omission by management to afford the necessary skills. Education in investing should begin the first year of employment, with annual updates thereafter. Remember, TSP is no longer a "savings" program once out of the G-Fund. However, management will provide for TSP investing education, once it becomes "important" to them. TSP is an option to many in management, remember they are mostly under CRS, not FERS. They do not have to manage investments in completing their retirement goals.

Spaf -

Nearly all employees of my agency, to include management, are covered under FERS, and therefore have a vested interest in the TSP. The government is not obligated, nor should they be in my opinion, to "educate" employees of the pros and cons of investing, and/or the finer working details of the TSP. The onus clearly rests on the employee to make his or her own decisions, whether publicly or privately employed. The last thing I want are our tax dollars being used for is for "educating" the mass of the federal workforce; I'd rather those tax dollars be spent productively for the benefit of those we serve - the American people.

I also respectively disagree with the notion that FERS employees should be dissatisfied with the TSP. I think a lot of federal employees who have established retirement goals and are active in preparing to reach said goals are satisfied with the TSP, and particularly enjoy the low administrative costs associated with the TSP. I think there is a misperception among some active traders that anyone who doesn't actively trade is uninformed, uneducated, or as some seem to imply, intentionally misinformed about investing options. While I agree there are scores of TSP participants that are woefully uninformed of how TSP works, and how the TSP can potentially be a major player in their respective retirement, on the balance I think most TSP participants know what is going on and willfully choose the passive investment route because it fits well into their investment/retirement goals, primarily because of their accepted risk tolerance.

I have been with Uncle Sugar since 1999, and a TSP participant since eligibility. Obviously, I haven't been around since the inception of the TSP, but unless I'm missing something, the TSP was never designed nor intended to be an investing vehicle akin to an active brokerage account. (I'd be interested to know how IFT's were accomplished prior to the TSP website IFT capability)

The restrictions on the IFT's to just two a month is sufficient for a lot of TSP participants' investing plans, wherein only periodic IFT's are needed to satisfy their respective rebalancing amongst their chosen funds. Assuming that active trading incurs additional expense to the TSP, and that that assumed additional expense is then borne by all participants of the TSP, is something that I don't really find quite fair. Why should passive participants, who by definition generally do very few IFT's, have to sharer the cost for those that actively trade? Now, I am assuming that there are additional costs - if not, please advise.

 

[XL-entLady]

OBGibby, it appears from your posts that you work for a progressive agency and with well-informed co-workers. I congratulate you for that.

My own experience was somewhat different. I got my permanent status 6 days too late to be a CSRS employee. FERS is a great retirement program if you work for the government for a while and then leave for private industry, because it is portable. But it can be a challenge too.

In my case, my agency was not a progressive one and there was institutional unhappiness with FERS because of the added personal services costs. Until my last decade of work, people in management positions were CSRS and could plan that they would get x% of their active duty pay in retirement with their TSP accounts just being pin money. I tried to get information about the TSP and before the advent of the website, the information available to me was a couple of pages of handouts that told what TSP was but not much about how to use the funds to my advantage.

I attended one government sponsored retirement seminar in my years of service, in 1999. That seminar spent about an hour on TSP accounts, and my notes from that hour contain such platitudes as, "Stocks have done better than any other investment in any decade since inception, including any decade that includes 1929." In that seminar we were told to leave half our TSP account in G and put half in C and forget about our account until we were within 5 years of retirement, then to move 10% per year from C to G so that it was all in G when we retired. So I did what the expert said.

I looked at my yearly statements in 200 and 2001 with concern but still held to the party line. Finally in 2002, I decided that as little as I knew about things, I apparently knew more than the expert who had advised us in 1999. By that time, C Fund had dropped by 40% over the last three years while F Fund had gained 30% over those same three years, for a 70% difference.

I gradually became a swing trader and have been able to beat the markets in each of the last six years. But now I am one of the first FERS retirees and am struggling with the challenge of a TSP account that (although sizeable) is not big enough to last decades unless I can figure out how to preserve capital instead of drawing it down.

I do not think I was intentionally misinformed about my TSP account in my active duty years. I think that in the rural outposts where I spent the first two decades of my service, nobody was informed and general information has only been available for the last decade or so.

I do not think it is fair for TSP investors (people who buy-n-hold) to stand the costs for the IFTs of the TSP traders. But a "per IFT" charge against a TSP account for any IFTs over those currently allowed would be a simple solution to that problem. As it stands now, I educated myself about swing trading so that I would know how to make my account last the way I need it to, and then the rules changed so that I can't do that. I'm not given any options except like it or leave. How fair is that?

It is probable that as more management types begin to retire under FERS and realize the challenges, the rules will change to allow real time trades and to be able to buy trades as needed. I hope there is still enough of my TSP account left at that point that it still matters to me.

Lady

 

[OBGibby]

Lady -

I agree that additional IFT's should be available on a per-cost basis. Do you, or anyone else, know what the industry average would be in terms of cost per trade?

Additionally, what options do you (Lady) have relative to rolling your entire balance over to an IRA? Would it be worth it to you to transfer your funds, even if penalties were involved?

 

[James48843]

Lady -

I agree that additional IFT's should be available on a per-cost basis. Do you, or anyone else, know what the industry average would be in terms of cost per trade?

Additionally, what options do you (Lady) have relative to rolling your entire balance over to an IRA? Would it be worth it to you to transfer your funds, even if penalties were involved?

OBgibby:

You ask "Do you know what the industry average would be in terms of cost per trade?"

The answer to that is- it should have nothing to do with "industry average". It should be based on actual costs instead.

For example- the TSP has an annual cost of about 3 basis points to manage all of the more than $200 billion dollars. That includes costs for trades, costs for administration, the call center, employees, etc.
That cost has been heading down since the plan's inception.

The industry average is, on the other hand, more like 65 to 80 basis points for administrative fees. So, you see, comparing the costs in TSP to "industry average" to set prices is not valid.

Now, when you look at actual costs, it's on the order of around $6 per trade. That's from the TSP Thrift Board's own data. The cost for trading the I fund is higher than the others, because some countries (notably ireland, at 1%) impose a transfer tax on each stock trade. However, the C fund (S&P 500) has exceptionally low costs-- pennies on the trade. So, anyway, it averages out to less than $6 a trade overall.

Now, should people be allowed to manage their own money? Absolutely. Since we put the burden on people to control their own retirement when CSRS was changed, we owe each employee: 1. Educational opportunities, so that they understand how the system works, and 2. A free market in which to exercise their own values, education, and goals.

Sure, some people are "buy and hold". If they know what they are doing, and are making a conscious decision to be "buy and holders", then more power to them.

On the other hand, if someone wishes to take a different amount of risk, then they should be allowed to use the full power of the TSP system to their own benefit.

You ask "Would it be worth it to transfer your funds, even if penalties are involved?"

The answer to that is- it depends. For someone who has successfully amassed a significant balance, and who is able to move funds regularly in a new account, then yes, it very well may be.

Except under TSP, the only way to be able to move funds away from the TSP is to separate from your job. And many are now considering doing that, just to have that freedom to invest as they see fit.

The total cost of all trades in 2007 was on the order of 23 million dollars. That's on tens of billions moved. If they had a $5 fee, they would be able to easily cover the costs involved, and everyone I know who used to manage their own money would not object to a $5 fee.

Except that is beyond the thinking of the Thrift Board, and Tracy Ray's mentality of "buy and hold".

You asked "What did we do before the website for trades?"

The answer is- we only could trade once per month.

Then we invested hundreds of millions of our dollars- TSP member dollars- to build a system that provided for a daily valuation and execution of trades.

and then the Thrift Board negated that hundreds of million dollar investment, by turning the clock backwards and locking us out.

 

[XL-entLady]

Lady -

I agree that additional IFT's should be available on a per-cost basis. Do you, or anyone else, know what the industry average would be in terms of cost per trade?

Additionally, what options do you (Lady) have relative to rolling your entire balance over to an IRA? Would it be worth it to you to transfer your funds, even if penalties were involved?

A discount brokerage (one where you execute your own trades instead of working with an advisor) charges from $7 to $10 per trade. Some companies such as Zecco charge a monthly fee of around $30 which gives you 10 or so free trades before you need to purchase any.

In a normal financial environment, it would be worth it to me to take the tax penalty and transfer my funds. I could make the tax penalty back because of the freedom I would gain to trade as needed. I know this is the case because I track trades I would have made if I could, so that I can ensure that I am learning what I need to learn. In the last 4 weeks, my account would have gained 10% if I had made 4 more trades than I am currently allowed.

However, in this environment I cannot take the chance that I would move my account into the one company that would go bankrupt and not be rescued by the government. I need to stick with TSP that is backed by "full faith and credit" until things stabilize. It's one of those "stuck between a rock and a hard place" things. :worried:

Lady

 

[Spaf]

Spaf -

Nearly all employees of my agency, to include management, are covered under FERS, and therefore have a vested interest in the TSP. The government is not obligated, nor should they be in my opinion, to "educate" employees of the pros and cons of investing, and/or the finer working details of the TSP. The onus clearly rests on the employee to make his or her own decisions, whether publicly or privately employed. The last thing I want are our tax dollars being used for is for "educating" the mass of the federal workforce; I'd rather those tax dollars be spent productively for the benefit of those we serve - the American people.

I also respectively disagree with the notion that FERS employees should be dissatisfied with the TSP. I think a lot of federal employees who have established retirement goals and are active in preparing to reach said goals are satisfied with the TSP, and particularly enjoy the low administrative costs associated with the TSP. I think there is a misperception among some active traders that anyone who doesn't actively trade is uninformed, uneducated, or as some seem to imply, intentionally misinformed about investing options. While I agree there are scores of TSP participants that are woefully uninformed of how TSP works, and how the TSP can potentially be a major player in their respective retirement, on the balance I think most TSP participants know what is going on and willfully choose the passive investment route because it fits well into their investment/retirement goals, primarily because of their accepted risk tolerance.

I have been with Uncle Sugar since 1999, and a TSP participant since eligibility. Obviously, I haven't been around since the inception of the TSP, but unless I'm missing something, the TSP was never designed nor intended to be an investing vehicle akin to an active brokerage account. (I'd be interested to know how IFT's were accomplished prior to the TSP website IFT capability)

The restrictions on the IFT's to just two a month is sufficient for a lot of TSP participants' investing plans, wherein only periodic IFT's are needed to satisfy their respective rebalancing amongst their chosen funds. Assuming that active trading incurs additional expense to the TSP, and that that assumed additional expense is then borne by all participants of the TSP, is something that I don't really find quite fair. Why should passive participants, who by definition generally do very few IFT's, have to sharer the cost for those that actively trade? Now, I am assuming that there are additional costs - if not, please advise.

Well, a specific reply to me......

Answer: OB, sorry, I can't agree with you!

Maybe we should go back and re-read what Steve said in his post # 1. for this thread..... "I wrote this story yesterday on data showing that thousands of TSP participants are deciding to stop putting their money in the plan......"

RE: Post and Story ----> http://www.tsptalk.com/mb/showpost.php?p=199081&postcount=1

In your quote I seem to get that you don't want to use tax dollars to educate TSP participants because most participants willfully choose the passive investment route and assume the risk. And, participant traders are assumed to create excessive expenses from frequent Inter Fund Transfers, IFT's.

Normally, You will find me silent on various opinions and issues. However, your specific reply did deserve an answer.

In respect
S

 

[OBGibby]

James/Lady -

Thanks for the information. I was more specifically inquiring as to the average price for transactions within TSP-like progams, such as similar IRA's and 401K's, but your numbers were informative nonetheless. I agree with the notion that any cost attached to a TSP transaction should reflect an accurate transactional cost incurred by the TSP. Can you point me in the right direction regarding how the upgrades to TSP you mentioned where financed? And, how long ago did the once a month IFT change with the addition of the web-based unlimited IFT's, before reverting to the current two-a-month IFT?


Spaf - In my earlier post I advocated not having the government expending resources unnecessarily on educating federal employees on the benefits of controlling major portions of their retirement. My position is irrespective on whether a federal employee is an active trader or a passive investor. It has been my experience that the current guidance given by government agencies to their employees is sufficient. At some point individuals have to take personal responsibility for their own futures, and Uncle Sugar cannot and should not be the omnipresent force for all things, to all people.

 

[James48843]

James/Lady -

It has been my experience that the current guidance given by government agencies to their employees is sufficient. At some point individuals have to take personal responsibility for their own futures, and Uncle Sugar cannot and should not be the omnipresent force for all things, to all people.

I have worked for the federal government since 1992. I have never received any training or information about the TSP, with the exception of a couple of flyers telling me is was "open season" in 1993 and 1994. And, of course, the infamous $4 million dollar CD distributed to all TSP holders in 2006.

Nothing. Nada. Ziltch.

That is par for the course at my agency.

 

[James48843]

James/Lady -

Thanks for the information. I was more specifically inquiring as to the average price for transactions within TSP-like progams, such as similar IRA's and 401K's, but your numbers were informative nonetheless. I agree with the notion that any cost attached to a TSP transaction should reflect an accurate transactional cost incurred by the TSP. Can you point me in the right direction regarding how the upgrades to TSP you mentioned where financed? And, how long ago did the once a month IFT change with the addition of the web-based unlimited IFT's, before reverting to the current two-a-month IFT?
.

The system was changed to unlimited IFT's in 2003, after a five year blown program with two different contractors. YOU are paying for the new system, and for the fialed contractors attempt. Read this: http://govexec.com/story_page.cfm?filepath=/dailyfed/0603/062303t1.htm

There was a legal battle over the cost over runs from the first contractor, AMS, which was hired in 1997 to create the new system. They were fired in 2001 after huge cost over runs, and failed software code. They turned around and sued TSP for $350 million. It took two more years and 40+ million more dollars to come up with the system we have today, which allowed unlimited moves.

Up until, that it, the current Thrift Board took that away.

Here is another article on the changes, from the summer of 2002:

http://govexec.com/story_page.cfm?filepath=/dailyfed/0502/051702b1.htm

 

[James48843]

ANd here is another article about what happened when the went to the new system:

http://www.govexec.com/story_page.cfm?filepath=/dailyfed/0803/081803t1.htm

By the way- that article mentions that is costs $6 million per year to mail participant statements back in 2002. I would think that now that number probably is much higher due to postal service rate hikes. However, the costs involved in ALL the frequent trading were lower than the costs to mail participant statements. Yet Tracey Ray and Greg Long decided that the costs were "too high" to allow us to control our own money.

Sorry I ramble- but this is a sensitive topic for me.

I don't like having to invest hundreds of millions of dollars for a system, only to have someone later come along and decide that they know better how I should handle my money, and then negating the investment that WE are still paying for.

 

[OBGibby]

James -

No need to apologize for the rant or your passion for the subject at hand. As I've stated before, I do appreciate the point of view you and others hold, I just don't necessarily agree with it.

In an earlier post you mentioned that the TSP spent hundreds of millions of dollars to upgrade the computer systems, and that those costs were than passed on to the TSP participants. The articles you linked identified significant amounts passed on to participants, but not nearly in the ballpark of hundreds of millions. What am I missing? I'm not too proud to admit my ignorance or my inability to read between lines!

If I have this right, prior to 2003, TSP participants were limited to only one IFT per month, or twelve per year. The new system comes on-line, and unlimited IFT's were permitted. In 2008, the IFT's were limited to basically two per month. So, we're back to square one, which on the face of it smacks of unfairness and regressive policy. However, on the flip side, when the unlimited IFT's came on-line as a result of the new computer system, it was never intended to facilitate unlimited active trading. While it is true the computer system may functionally be able to handle active trading, the costs involved with active traders appear to outweigh the benefit to the TSP participants as a whole (at the current no cost per trade basis).

I'm still inclined to think that most 401Ks restrict or impose fees to discourage active trading - not because it's some evil conspiracy on the part of the respective 401K board, or stems from, as some would have us believe, the incompetence of the 401K board, but because it's costly to plan participants as a whole and detrimental to the long-term investment returns of the vast majority of the plan participants.

 

[James48843]

James -
However, on the flip side, when the unlimited IFT's came on-line as a result of the new computer system, it was never intended to facilitate unlimited active trading. While it is true the computer system may functionally be able to handle active trading, the costs involved with active traders appear to outweigh the benefit to the TSP participants as a whole (at the current no cost per trade basis).

Wrong. It was DESIGNED to allow unlimited IFTs. That was a software design requirement. IT was required to handle up to one trade PER DAY per TSP shareholder. Along with the ability to cancel trades, or change trades. It was in the software requirements document in 1997.

"...costs involved with active trading..."

Let me clear this up again- the costs are minute. Small, tiny. In some cases, they actually MAKE money by trading- not COSTING money to trade.

99% of the costs do not exist. That's because the system balances, in the computer, WITH THE TSP - those selling and those buying each day, BEFORE the net bulk order goes out to Barclays to buy or sell certain numbers of shares.

Let's say 1,000 want to sell today. THey want to sell evey single share of S&P 500 they own. And then let's say 900 want to BUY today.

There are not 1,900 buy and sell transactions that take place. 900 of the buyers and sellers are matched on the computer software between noon and 2:30 each day. And so there is NO COST to the TSP for them.

That leaves only the actions of 100, out of 1,900 trades, that will actually have to be executed on the open market.

And it isn't 100 individual transactions that take place. It's ONE transaction, of 100 shares, that takes place, between 2:30 p.m. and 4 p.m.

As far as the TSP is concened, it doesn't cost any more if they are buying 1,000,000 shares, or 100,000 shares. It's ONE transaction.

OK- there is incremental costs, pennies, actually, in the difference between trading a million shares, and trading 100,000 shares. Barclays has it down to a science, and , in a falling market, buys shares late, or sells shares early in the 2:30 to 4 p.m. period. IN a rising market, they do the opposite. The "Value" is placed on the trades at 4 pm.

Barclays makes MILLIONS of dollars on some days on this movement.

they lose a little on other days.

But overall, they win big.

The actual NET costs are reported in the monthly printouts as "tracking error".

For example, in October, the "tracking error" was reported in the monthly minutes as follows:

The Barclays Extended Equity Market Fund E underperformed by 47
basis points in October and outperformed by 35 basis points
year-to-date. The performance difference is primarily related to
the sampling technique used by the Fund. The Barclay’s EAFE
Equity Index Fund E underperformed by 40 basis points in October
primarily because of a fair valuation adjustment on September
30. The Barclays U.S. Debt Index Fund E has outperformed by 12
basis points in 2008, primarily as a result of the sampling
technique used by the Fund.

Here is a breakdown of the trading costs for the month of October. Now, remember, October 2008 was pretty wild. Lots of people moved funds.

View attachment 5305

As you can see, some 2 BILLION dollars was traded in the C fund in October 2008.

And the total cost to execute all those trades? Just $223 thousand dollars.

That means it that cost $1 to trade each $10,620 of funds traded into or out of the C fund in October.


And the I fund? Well, because of what I just explained, costs for trading the I fund were actually NEGATIVE for October, 2008.

In October 1.538 BILLION dollars was traded. And it resulted in NEGATIVE costs of more than $8 MILLION. That means $8 million in EXTRA profit for I fund holders during that time. Meaning that the I fund MADE $1 profit for each $173 dollars traded.

If there had been unlimited trades in October, and the I fund had moved the same volume as in October 2007, you can bet there would have been a lot MORE money made.







​

 

[James48843]

Now, compare the costs for 2007 with the costs for 2008.

Look carefully. Compare each grouping.

First, let's look at the total amount of funds traded in 2007 vs. 2008. Remember, the new rules went into effect in April, but the Board pulled the trading privileges of thousands of us in February:

View attachment 5306​