Dear Frequent Trader:
As explained below, you have been identified as a frequent trader in the Thrift Savings Plan. Unless you reduce your trading activity to no more than 3 interfund transfers per month, we may require you to request interfund transfers by mail only.
Since the Thrift Savings Plan introduced daily valuation of participant accounts in 2003, it has not restricted the number or frequenct of participant-iniated interfund transfers. However, recently, the frequent trading activity of a small number of participants is resulting in higher transaction costs and reduced return for all participants in the affected TSP Funds - including long term investors who do not generate these costs. Frequent trading is also creating greater risk of performance deviation from the TSP Funds benchmark indexes.
By law, the Federal Retirement Thrift Investment Board (which administers the TSP) is required to develop investment policies which replicate the performance of the indexes selected for investment and provide for low expenses. Because frequent IFT activity diminishes the achievement of these goals, the Board is addressing the problem in two ways - (1) Structural changes to the TSP system to implement restrictions on the number of interfund transfers that can be executed per calandar month, and (2) intermin measures designed to lower trade volume in the meantime.
In November 2007, the Board approved a policy initiative that would permit two IFTs per calander month, with subsequent unlimited IFTs into the Government Securities Investment Fund. When compared to the more restrictive limits adopted by private sector defined contribution plans, record keepers, and/or investment fund managersm, this approach provides investment flexibility, administrative simplicity, and control over excessive trading.
Further, based on current behavior, approximately 99% of participants will not be affected by the proposed restrictions. We will soon publish proposed implementing regulations for public comment. The Federal Register notice will include a description of the problem, the restrictions established by other funds/plans, and our proposed solution. We will consider comments as we move towards resolution o this matter in the Spring of 2008. We are also notifying all participants of the proposed changes when we send the annual TSP participant statements in February, 2008.
Our immediate concern, however, and the reason for this letter to you, is the reduction of trading activity among those participants who trade most frequently. Based on the authority granted to the Executive Director to take appropriate action to restrict frequent interfund transfers, we are contacting those participants who have made frequent IFTs and asking them to voluntarily change their investment strategies.
Because in October, Novermber and December 2007, you made more than three IFTs each month, you fall within this frequent trading group. Therfore, unless you reduce your IFTs to no more than three per month (starting in February) we may notify you that you will be required to request your IFTs by mail until the permanent restrictions have been implemented. This proceedure is authorized by Federal Regulation 72 Fed, Reg. 73,251 (Dec 27, 2007) (to be codified at 5CFR 1601.32). We are asking for your cooperation in this matter.
We have posted a set of Questions and Answers about the frequent trading activity, as well as the November 6, 2007 memorandum to the Board, and it's accompanying presentation, under "Information about Interfund Transfer Restrictions" on the TSP Web site's Home page (
www.tsp.gov). Links to the regulation cited above can be found at
www.frtib.gov and
www.tsp.gov ("What's New" or "Information about the Interfund Transfer Restrictions"). We will also post a link to the proposed regulations regarding the structural restrictions when that issuance is published in the Federal Register.
We strongly encourage you to read these materials so you understand the impact of your frequent trading activities and the reason we are taking these actions. If you have any questions regarding this letter, you may contact the TSP at 202-942-1460.
Sincerly,
Gregory T. Long
Executive Director