What YOU can do to fight back - IFT limit

[James48843]

Ask your Union what they are doing about it. Look up your Union HQ's number and ask to talk to the Union President or VP.

Get them involved.. NOW!

 

[Art2007]

FAXED just now:


Reference Federal Register notice, FR Doc. E7-25007 Filed 12-26-07; 8:45 am

Dear Sirs:

Please do not invoke trade limits. Your math is wrong. How much do you think you can save by limiting trades?

More than 2,500 people have already signed the petition at http://tspshareholder.org, telling you that this is WRONG. IN addition, your federal register notice says this will only affect federal employees. This is wrong.
It will affect retirees, U.S. Military service members, as well. And it will affect their spouses and families.

And, contrary to your notice, it WILL affect a substanital number of small entities.
There are 3.8 million shareholders. And there are now dozens of investment conselors and financial professionals, who advise TSP Share Holders about their holdings. Your notice will adversely affect the sales and business of MANY small entities, if the client they support can no longer make moves based on their advice. The affect will be to put many out of business.

Your "Interim Rule" also does not meet the legal requirements of the Administrative Procedures Act, in that there is NO EMERGENCY, and this "Interim Rule" violates 5 USC section 553.

You have not given the legally required 30 day comment period and notice of proposed rule making;

Your rule amounts to a "sanction" against certain participants in the TSP. Under 5 USC Section 558, you may not sanction without conducting a public hearing on the matter, and obtaining public input.

Please retract your Federal Register notice.
Sincerely,

JAMES: THIS IS VERY GOOD STUFF. I AM GOING TO ASK OUR ADMINISTRATIVE LAW ATTORNEY TO LOOK THIS OVER FIRST THING IN THE MORNING.

 

[Art2007]

James:

If This Action Is Illegal Or Could Be Illegal, Can We Not Appeal This To The Solicitor General Or Comptroller General?

 

[RAE]

Ask your Union what they are doing about it. Look up your Union HQ's number and ask to talk to the Union President or VP.

Get them involved.. NOW!

Here is the FAX I just sent. I borrowed liberally from several folks who provided comments about this, earlier in this thread (thanks). Paladin, if you are out there, we could use your input on this also.....are we missing anything that might be important?
_________________________________________________________________
Dec. 28, 2007
Mr. Emswiler:

I am commenting on the proposed Interim Rule posted to the Federal Register (FR) by FRTIB on Dec. 27, 2007. The FR Document number is E7-25007, and this rule pertains to 5 CFR Part 1601 – Participants Choices of TSP Funds.

This notice is invalid for several reasons and should be withdrawn. It does not meet the requirements of the Administrative Procedures Act or the Regulatory Flexibility Act. It does not meet the requirements of "emergency rulemaking" (nor does it state that it is an emergency rule) so can't bypass the NPRM process. I have summarized these regulations below:
___________________________________________________________________
”A notice of proposed rulemaking or NPRM is issued by law when a regulatory agency of the United States Federal Government wishes to add, remove, or change a rule (or regulation) as part of the rulemaking process.
NPRM procedure is required and defined by the Administrative Procedure Act. The Constitution does not require NPRM. Rather, Congress created the requirement to enlighten agencies--that is, to force them to listen to comments and concerns of people who the regulation will likely affect.

The NPRM is published in the Federal Register and typically gives 60 days for public comment from any interested party, and an additional 30 days for reply comments. Original comments may still be filed in the reply comments window. While this is the normal method of agency rulemaking, emergency rulemaking is allowed to bypass the NPRM process.

About Notices of Proposed Rulemaking: (a) Each notice of proposed rulemaking is published in the Federal Register, unless all persons subject to it are named and are personally served with a copy of it.
(b) Each notice, whether published in the Federal Register or personally served, includes:

1. A statement of the time, place, and nature of the proposed rulemaking proceeding;
2. A reference to the authority under which it is issued;
3. A description of the subjects and issues involved or the substance and terms of the proposed regulation;
4. A statement of the time within which written comments must be submitted; and
5. A statement of how and to what extent interested persons may participate in the proceeding.” ______________________________________________________________

I note that Item #4 above was not met – the Notice does not state the time period within which written comments must be submitted (stating that the Rule will be effective on January 7, 2008, is not the same as defining a comment period).
Further, I object to the fact that this proposed interim rule was published between the Christmas and New Year’s holidays, when many Federal employees are on leave and unaware of this action
Further, I object to the fact that you have not provided a means to provide comments electronically, via an internet-based comment window, in response to this proposal. It is common practice to all for comments on proposals such as this via such a comment window attached to the rule; to not do so is unreasonable, and gives the appearance that FRTIB is attempting to minimize the number of comments received.
Further, the proposed rule does not contain a clear, impartial and transparent way of how the Board identifies the 3000 TSP members that they are proposing to send the letter to; therefore it could easily be misused and arbitrary. Before any such letters are sent, there needs to be a very clear set of criteria that need to be demonstrated for each of the Fed Employee that the Board proposes to send a letter to.
Finally, the statements that the regulations…. “will not have a significant economic impact on a substantial number or small entities. They will affect only employees of the Federal Government”….are incorrect. Federal retirees are also impacted by this proposed regulation, and the proposed regulation certainly WILL HAVE a significant economic impact on at least some TSP participants.
I also do not agree with the basic premise outlined for the necessity of this Interim Rule. The FRTIB has not provided a complete accounting of TSP expenses, including trading expenses, so that a fair and objective evaluation can be made as to the degree that overall TSP expenses are changing. The conclusion that some 3,000 frequent traders are causing TSP expenses to spike, is speculative and unsupported, based upon the data provided to date. This Interim Rule will lead to severe restrictions on the ability of TSP participants to manage their retirement funds. Such a drastic change is unwarranted without a much more detailed and thorough examination of the data on TSP expenses, and also an examination of a range of alternatives for addressing this (perceived) problem, if a problem is even identified.
The existing rule allowing unlimited interfund transfers, which could be made via letter, via internet (TSP website), or via the Thriftline, was put in place several years ago to allow TSP participants the flexibility to manage their retirement funds as they see fit. It is a fundamental part of the process for managing one’s TSP account, and was heralded at the time by TSP as a great improvement to the system. The justification provided by FRTIB to date for modifying this rule is clearly insufficient for making such a severe change. Until a much more complete accounting of TSP expenses is provided, and alternative solutions to any perceived problems are explored (including soliciting input from TSP members), this proposal must be withdrawn. Further, no letters should be sent to so-called frequent traders warning them of impending restrictions on their ability to make interfund transfers.
For all of the reasons cited above, I hereby request that this Interim Rule be withdrawn.

Sncerely,
XXXXXXXX

 

[Art2007]

Wow James! Spoken like a true fed.

I have the name and fax number of the Comptroller General. His office reviews all Fed Register proposed rules and provides comments to the agency within 7 days.

I am goiong to bring the legal and procedural errors to the CG GAO's attention first thing in the morning.

[FONT=LLFMF G+ Helvetica]Comptroller General [/FONT]
[FONT=LLFLK I+ Helvetica][FONT='LLFLK I+ Helvetica']David M. Walker[/FONT][/FONT]
[FONT=LLFLK I+ Helvetica][/FONT][FONT=LLFLK I+ Helvetica][FONT='LLFLK I+ Helvetica']FAX (202) 512-5507[/FONT][/FONT]
[FONT=LLFLK I+ Helvetica][/FONT]
Government Accountability Office
441 G St., NW
Washington, DC 20548

 

[James48843]

James:

If This Action Is Illegal Or Could Be Illegal, Can We Not Appeal This To The Solicitor General Or Comptroller General?

No Art, we can't.

The appropriate recouse, according to the Administrative Procedures Act, is to file suit in federal court. I posted earlier today the citations of Title 5 that are required to be followed. It starts with 5 USC 553, and continues in other 5 USC sections that follow that. In short, the United States Code is the law, and is what has to be followed. They are doing what amounts to a sanction against individuals, the right to place money where people see is best for their own purpose. And a 'sanction" has it's own appeal process which is required to be followed. The law provides for that. And the law provides, that when it is not followed, that a person can bring suit against a government agency in Federal Court.

Now, I have done my best to help others organize a response. I have worked my tail off, researched, discussed, strategized, asked for and received a lot of input from a lot of people, and done my darndest to keep everyone informed, and asked only in return that YOU tell each of your coworkers how vitally important it is that THEY get involved. That THEY each tell someone else that their very retirement plan is under attack. That the math simply does not add up, and that their livelyhood is about to be blown away.

And now, the recourse for this violation in law, is to file in federal court, ask for an injunction againt this rule's date of effect on January 7th. Even if successful, that only buys us a little time.

I'm sorry, but I don't have the capital $ to hire an attorney and do that.

The BIG battles lay ahead.

And I am about out of energy for a few days. I've been working litteraly around the clock for the last five days, while on Annnual Leave, to do research, put together newsletters, try to do the math, consult with team mates on strategy, and come up with the best way to inform the masses and motivate them to respond. There are 3.8 MILLION members of the TSP. And only 2,596 of them have signed the petition so far. And only about a hundred have "chiped in" to fight this impingment of freedom.


I am one small guy, sitting at one lonely keyboard, tapping out my heart, talking to other small guys (and gals), sitting at their keyboards, tapping their hearts out, all of us trying to get people to see that the math simply does not make sense. People- WAKE-UP!

This is YOUR freedom and YOUR rights that are about to be slammed, and the math simply doesn't make sense.

I have even gotten "hate mail" from a half-dozen "G" fund apes who don't know any better, who think we are taking THEIR money away from them, 'cause that is what the TSP told them.

No Art, we can't depend on a Bush Administration Appointee "solicitor general" to ride to the rescue. The "Solicitor General" handles cases before the U.S. Supreme Court, and appeals from lower courts. This isn't in court. Yet. See: http://www.usdoj.gov/osg/ for the duties of the "Solicitor General"

The "Comptroller General" is of little use in this matter either. All they do is, upon request of a Congressional leader, is to review policies and report back to members of Congress what they find. They last took a look at the TSP here: http://www.gao.gov/htext/d07611.html They don't have the power to order TSP to do anything.

Sorry I sound frustrated, but this is a long war, and there will be many battles and many fights. The key is that we are right, and we hold the moral high ground. This is STILL America.

We have to educate 3.8 MILLION other TSP shareholders, and somehow move THEM into action to protect their own rights. Motivate THEM to take action to protect the rights and gains that others before them have won.

How do we do this?

That becomes the question.

I'm signing off for the night- it's been a long day, up since 4 a.m. tapping away. I've not moved anything in my own account since November, when the word of this COUP broke out. I've been too busy trying to organize people to fight back, that I haven't had time to watch my own account, which, by the way, would have been better off if I had moved off to the sidelines at the begining of the month, had I had the time to watch it properly. No, it's time for a break.

It's time to go play with my son and my dog.

Good night, and good luck.

 

[Art2007]

Thanks James!

We will keep plugging along. I have been on the phone all day to the Congressional Committees and the individual offices of the Senators and Congressmen on those committees. Unbelievable how everything in the beltway is parylized during the holidays. Bet TSP counted on that one.

I talked by email twice today with Ms. Ray. Can't believe she never mentioned this filing in our discussions.

Unfortunately, TSP seems to be doing whatever they want without working or communicating with the customers, much less their own advisory board.

iT IS 1 A.M. HERE iIN EUROPE SO i'M OUT OF HERE!

 

[Miss_Piggy]

..... And I am about out of energy for a few days. I've been working litteraly around the clock for the last five days, while on Annnual Leave, to do research, put together newsletters, try to do the math, consult with team mates on strategy, and come up with the best way to inform the masses and motivate them to respond. There are 3.8 MILLION members of the TSP. And only 2,596 of them have signed the petition so far. And only about a hundred have "chiped in" to fight this impingment of freedom...

I am one small guy, sitting at one lonely keyboard, tapping out my heart, talking to other small guys (and gals), sitting at their keyboards, tapping their hearts out, all of us trying to get people to see that the math simply does not make sense. People- WAKE-UP!...

This is YOUR freedom and YOUR rights that are about to be slammed, and the math simply doesn't make sense.

I have even gotten "hate mail" from a half-dozen "G" fund apes who don't know any better, who think we are taking THEIR money away from them, 'cause that is what the TSP told them...

I'm signing off for the night- it's been a long day, up since 4 a.m. tapping away. I've not moved anything in my own account since November, when the word of this COUP broke out. I've been too busy trying to organize people to fight back, that I haven't had time to watch my own account, which, by the way, would have been better off if I had moved off to the sidelines at the begining of the month, had I had the time to watch it properly. No, it's time for a break.

It's time to go play with my son and my dog.

Good night, and good luck.

Truly. Sincerely. Thank You, James!​

 

[Art2007]

This went to the Comptroller General anyway:

Dear Mr. Walker:

I am extremely concerned about the legality of a proposed rule made yesterday by the Federal Retirement Thrift Investment Board in Federal Register notice, FR Doc. E7-25007 Filed 12-26-07; 8:45 am. As you pointed in our in your most recent GAO report number GAO-07-611 released on July 23, 2007, the Thrift Savings Plan is one of the largest pension plans in the world. You also pointed out that there is no regular Congressional or DOL oversight over the Board and its activities.

The proposed rule appears to give the Board unlimited authority to SANCTION any federal employee or TSP participant they choose which could have substantial adverse financial impact on the participant without the due process required for such sanctions under 5 USC Section 558.

The proposed rule was published between the Christmas and New Year’s holidays, when many Federal employees are on leave and unaware of this action. More importantly, Congress is not in session and does not return until the day the interim rule becomes effective on January 7, 2008.

This very short comment period appears designed to avoid public scrutiny and Congressional oversight and may be a violation of the Administrative Procedures Act, in that there is no emergency, and this "interim rule" may violate 5 USC section 553 by not giving the legally required full comment period and notice of proposed rule making.

I also believe the interim rule also violates 5 CFR Chapter VI, Section 1601.22, paragraph (a) which governs daily interfund transfers.

I ask that you review this rule published in the Federal Register and take action you or your staff deem appropriate.

 

[DrFaustus]

There is something going on here that I don't understand.

The Board claims that the number of trades that is driving up the cost, the L-funds aren't contributing to that because they wrap up everything up into just one trade. However, as I understand it, Barclays charges based upon the actual dollar amount that is traded. Way back when I was in high school, we learned that if A = ( a+b+c ), then C(A) = C( a+b+c ).

So what am I missing? Barclays might be charging a nominal fee for each trade but, given the dollar amounts that are being traded, I'm sure it's lost in the noise.

If we're right, and it is the L-funds that is driving up the cost, then restricting the number of trades people can make will have little impact on that - something the Board is bound to see in the next couple of years as their costs continue to rise. So we might see a relaxation in the trade restrictions somewhere down the road but I am betting it will be too late to help many of us.

 

[Show-me]

Just sent a note to ETAC and my elected officials.

Send a note to everyone so that they know about the underhanded crap the FRTIB is pulling.

 

[Art2007]

I am going to ask Ms. Ray by email if she can change the rules to allow us to do a "one-time opt-out" to an IRA as that would solve the problem. You can do this one time at age 60 or higher, so if they are going to change the rules, change this one also.

 

[MacDaddy]

I am a member of the AFGE Union. I have been in contact with my local rep and he has been forwarding this information to the National Headquarters. When I first contacted him he said the National Office had never even heard of any of this (Surprised face). I just forwarded the latest information regarding the interim rule change in hopes that they can jump in with a little more clout then we have at this time. I hope it helps.

I would like to thank all that have expended countless hours researching and corresponding with us and the managing agencies on this matter. I know there are a lot more people out there like myself that manage their own accounts but only read or don't post on here very often and I would hope that they are taking action as well.

Thanks again and keep at it. We WILL have to be heard eventually. Maybe not when we are expecting, but they can't dismiss us forever.

 

[Show-me]

Lets start pushing back. Here is a simple way to fax and it is free. Write something, anything in word then copy and paste it in the comments block. You will get a email confirming your fax. Click the URL and voilà off goes the fax.

http://faxzero.com/

ADDRESSES: Comments may be sent to Thomas K. Emswiler, General Counsel,
Federal Retirement Thrift Investment Board, 1250 H Street, NW.,
Washington, DC 20005. The Agency's Fax number is (202) 942-1676.

FOR FURTHER INFORMATION CONTACT: Tracey Ray on (202) 942-1665.

Contact you Congressional Offices and get the word out. The FRTIB is pulling a fast on trying to get this through over the Holidays while everyone is in vacation mode.

FIGHT PEOPLE FIGHT!

 

[07Harley]

This is what I faxed to Mr. Emswiler:



Dear Mr. Emswiler,The Thrift Board’s proposed Interim Rule to amend 5 CFR Chapter VI, Section 1601.32, paragraph (b) is inappropriate for the following reasons:(1) If the FRTIB would change the time that it posts share values from 7pm the day of the Inter Fund Transfer request to 7am the next day, the potential Fair Valuation problem that concerns the Board would not be an issue. Once the potential Fair Valuation problem is eliminated there would be no reason to limit IFT’s and no reason to take action against frequent transfers.
(2) The proposed Interim Rule contains no definition of what constitutes the practice of “excessive trading.” Therefore, the Executive Director has no way to determine which participants might be participating in the practice of “excessive trading.” This Interim Rule would allow the Executive Director to apply discriminatory restrictions to select participants based on his interpretation of “excessive trading”.
(3) Since there is no limit on the number of interfund transfer requests that may be made by a participant, there is no such thing as “excessive trading” under the current regulations.For the above reasons, I petition that the proposed Interim Rule be REPEALED.

Additionally, I respectfully request that you please read the following 2 online newsletters concerning the TSP.

http://tspshareholder.org/newsletters/Vol1_No4.html
http://tspshareholder.org/newsletters/Vol1_No5.html

Sincerely,

 

[Minnow]

I'm kind of conflicted here guys. On the one hand, I do believe in the process and writing to these folks and asking for reviews and audits and all really makes sense -- it's our right and if we feel we have been wronged, then why not take part in and try to use the democratic process? I have signed the petition and faxed/written so many people that I am just about sick of my own complaints. **note: still not giving up.**

On the other hand, I see how these people operate and they haven't done anything without the prior approval of their counsel. They have received legal advice galore (don't know how many on the board actually hold law degrees themselves) and will claim fiduciary duty until the cows come home and will most likely never be held accountable given a strict interpretation of their duties. It's slimy I know but if you think for one second that they aren't/weren't already anticipating a lawsuit, then you are fooling yourself. All these things that we are doing (i.e. writing our congressmen and senators, faxing the ETAC, etc.) are very admirable but the board has basically just thrown down the gauntlet or slapped us in the face with a duelling glove (however you want to look at it). They just slammed us and said, "If you don't like it, so what? Sue us!" We know they are monitoring this and the other website. You have to know that we are dealing with a worthy adversary here. It's all providing them access to our thought process and our future arguments. We need these forums to collectively and effectively communicate so I see no alternative to keeping them from meddling in our minds -- so to speak.

After we get the letters (Don't know if I will get one since I've traded alot but my balance is well below $200K) it seems then is the time to just say, "See you in court!" I'm not trying to say that arguing with them in the form of faxes, emails and phone calls right now is counter-productive but it might well be given that they have heard our arguments and have closed their ears and handled things the way they have. They seem confident in their position and would not have gone about things this way if their legal department didn't put their stamp of approval on it. I'm sure their General Counsel more than welcomes all comments as it gives him more ideas on how to effectively defend against our lawsuit when it comes. Again, the sliminess factor increased exponentially but as James (note: great work my man and I've had to go out and play with the kids and the dogs myself -- puts things in much better perspective, eh?) has pointed out, the only recourse is to file suit in federal court. If the TSP Board really wanted to hear from anyone, they would have followed the 60 day comment period but we all know that was and is not the case. They have taken an adversarial position and are not backing down. Any lawyer worth their retainer fee will tell their client that after you have exhausted the possible avenues of compromise, then it's best to just stop communicating and let the lawyers and the courts do their job -- still slimy but what's the alternative? **note: I still haven't given up.**

By the way, Happy New Year to all of you and may the New Year bring many smiles and blessings to all of you and yours (this includes you too TSP Board monitors).

 

[RAE]

I'm kind of conflicted here guys. On the one hand, I do believe in the process and writing to these folks and asking for reviews and audits and all really makes sense -- it's our right and if we feel we have been wronged, then why not take part in and try to use the democratic process? I have signed the petition and faxed/written so many people that I am just about sick of my own complaints. **note: still not giving up.**

On the other hand, I see how these people operate and they haven't done anything without the prior approval of their counsel. They have received legal advice galore (don't know how many on the board actually hold law degrees themselves) and will claim fiduciary duty until the cows come home and will most likely never be held accountable given a strict interpretation of their duties. It's slimy I know but if you think for one second that they aren't/weren't already anticipating a lawsuit, then you are fooling yourself. All these things that we are doing (i.e. writing our congressmen and senators, faxing the ETAC, etc.) are very admirable but the board has basically just thrown down the gauntlet or slapped us in the face with a duelling glove (however you want to look at it). They just slammed us and said, "If you don't like it, so what? Sue us!" We know they are monitoring this and the other website. You have to know that we are dealing with a worthy adversary here. It's all providing them access to our thought process and our future arguments. We need these forums to collectively and effectively communicate so I see no alternative to keeping them from meddling in our minds -- so to speak.

After we get the letters (Don't know if I will get one since I've traded alot but my balance is well below $200K) it seems then is the time to just say, "See you in court!" I'm not trying to say that arguing with them in the form of faxes, emails and phone calls right now is counter-productive but it might well be given that they have heard our arguments and have closed their ears and handled things the way they have. They seem confident in their position and would not have gone about things this way if their legal department didn't put their stamp of approval on it. I'm sure their General Counsel more than welcomes all comments as it gives him more ideas on how to effectively defend against our lawsuit when it comes. Again, the sliminess factor increased exponentially but as James (note: great work my man and I've had to go out and play with the kids and the dogs myself -- puts things in much better perspective, eh?) has pointed out, the only recourse is to file suit in federal court. If the TSP Board really wanted to hear from anyone, they would have followed the 60 day comment period but we all know that was and is not the case. They have taken an adversarial position and are not backing down. Any lawyer worth their retainer fee will tell their client that after you have exhausted the possible avenues of compromise, then it's best to just stop communicating and let the lawyers and the courts do their job -- still slimy but what's the alternative? **note: I still haven't given up.**

By the way, Happy New Year to all of you and may the New Year bring many smiles and blessings to all of you and yours (this includes you too TSP Board monitors).

Minnow - I'm not an attorney, but I do know that the way these things normally work, you must exhaust all avenues for comment and appeal, before litigation can be filed. If you have not exhausted all avenues, any lawsuit filed would be easily tossed out by any court as not having status (or whatever the proper legal term is). So, as tiresome as it sometimes feels to submit these comments, letters, etc.....it is our only avenue for being heard at this point, and one that we must utilize. I do believe that FRTIB made some administrative errors in the Fed. Register posting that they just made, and that it will have to be withdrawn. Perhaps Paladin or someone with more legal experience than me can chime in on this approach, but that is my belief and my understanding.

Don't give up the fight, guys. Progress often comes in small steps along a long road.

 

[Minnow]

Couldn't agree with you more RAE!!! Still keeping up the fight. Just taking pause to realize that these aren't chimps that we're dealing with. I would never be contentious with one of the TSPartans standing with me but for what it's worth, to file lawsuit, I believe you only have to claim that a specific wrong (tortious or otherwise) has occurred -- you don't have to exhaust the process -- just alledge that the wrong has occurred and I believe this will occur when the first letter goes out -- and by this time, the short comment period will be exhausted anyways and we will both be right. As always, I welcome any and all thoughts.

 

[Art2007]

TSP people may not be as smart as you think in all matters.

This whole mess will become a public relations nightmare. They misjudged their customers.

They obviously did not have much of a communnications plan on this. If so, you would have seen special announcements on their web site over a period of time defining the problem and then asking for cooperation. A good plan would have had their leadership talking about this in every major communications avenue for many many months to educate employees about the problem and their perceived affects. I give their public affairs effort a grade of D-.

Additionally GAO has been critical of the lack of regular oversight and hearings by the DOJ and Congress. This lack of regular accountability and their massive liability protections can make one pretty cocky.

Times inthe market have been good and the funds have been successful with this 4-5 year bull market, so who cares? Until now.

Memories are short in the Beltway where just a few years ago TSP was spending millions fixing their service, their web page, and fighting with the contractor....and so it goes.

 

[RAE]

TSP people may not be as smart as you think in all matters.

This whole mess will become a public relations nightmare. They misjudged their customers.

They obviously did not have much of a communnications plan on this. If so, you would have seen special announcements on their web site over a period of time defining the problem and then asking for cooperation. A good plan would have had their leadership talking about this in every major communications avenue for many many months to educate employees about the problem and their perceived affects. I give their public affairs effort a grade of D-.

Additionally GAO has been critical of the lack of regular oversight and hearings by the DOJ and Congress. This lack of regular accountability and their massive liability protections can make one pretty cocky.

Times inthe market have been good and the funds have been successful with this 4-5 year bull market, so who cares? Until now.

Memories are short in the Beltway where just a few years ago TSP was spending millions fixing their service, their web page, and fighting with the contractor....and so it goes.

I agree with you, Art. The TSP Board not only gets a D- for their communication and public affairs effort, but they are now demonstrating deceit and arrogance by posting this Fed. Register notice during the Christmas-New Year's holiday week, and trying to make the Rule effective on Jan. 7th, which is a clear attempt to sneak it through before most Feds even realize what is going on. The attitutude is..."we know what is best for you, and we don't really want any comments on this that disagree with us". I really think we should emphasize this behavior that they are demonstrating in our continued contacts with ETAC, Congress, and others. Even if they are right and there is a problem with trading costs (which I do not believe, since they have not proven their case), the way they have approached this whole situation displays a shocking degree of callousness and arrogance. This type of behavior alone shows that we clearly need new leadership at FRTIB.