What YOU can do to fight back - IFT limit

[weatherweenie]

I don't know if it will do any good, but I emailed my union's leadership, NWSEO, to ask what, if anything, they intend to do to protest the TSP board's decision to restrict transactions.

NWSEO's reply: 'we can protest this but we have no legal jurisdiction and therefore no influence.'

 

[ayla]

What is the real motivation behind restricting transactions to two a month?

IMO, their restriction is based on fear of their own incompetence. They are thinking (under the guidance of Ms. Ray) that they are following the big boys (i.e. a few funds that are using limits already, forget the fact that these funds have much much larger overhead than TSP and have shareholders that insist on profit and big salaries for the board members, not just that the funds cover expenses) .

Being a mindless copycat is enough to relieve them of some of their fear. The last thing they want to do is actually do the homework necessary to determine what is really the best path to take. Instead they get someone like Ms. Ray with an agenda (forget multiple people with multiple agendas coming to a consensus) to give them a sense that homework has been done. Heaven forbid, a real discussion and debate might take place on the best options here for everyone.

They have "outsourced" it in other words. A classic method for incompetent management to determine strategy. If it doesn't work out for the best, they can blame Ms. Ray (or better yet the contractors who are furnishing her info).

No accountability so why do actual real work to overcome any lack of information leading to their incompetence? Down the road when TSP participants no longer are maxing out their contributions but instead are taking what they would have given to TSP and investing in IRA's that give them real time trading with minimal costs for unlimited trades, the board members making this decision will be long gone (and as we know memories are always short.)

And I am totally convinced that "down the road", newcomers WILL be much more interested in trading their TSP than the current group who still have ties to the Depression mentality of keeping your funds in the G for absolute security.

 

[JonesH2O]

Jones,

I adopted and sent your letter to:

mailtoavidlRostker@omb.eop.gov

Airlift,

It cannot hurt. The more emails on this technical point sent to the Office of Management and Budget, the better.

 

[JonesH2O]

Jones,

What a beautiful brain you have! We need to use all legal avenues to stop the injustice, to stop the arrogance of power, and to bring accountability into process. Keep up the good work.

Thank you. I'm just "trying to stir the pot" by making arguments that the Federal Retirement Thrift Investment Board has to counter. If they cannot, then this action is withdrawn.

 

[Rod]

2) What is the real motivation behind restricting transactions to two a month?

ANSWER: There's not enough $$$ remaining in (G) for the gov. to "borrow" from.:notrust:

 

[Rod]

I brought it up to folks in my office and they immediately went on the offensive accusing us of "running of fees"- classic TSP Board propaganda.

If only they KNEW the potential earnings with their TSP- I tried to explain.

One can only TRY and lead a horse to water...

 

[weatherweenie]

I don't know if it will do any good, but I emailed my union's leadership, NWSEO, to ask what, if anything, they intend to do to protest the TSP board's decision to restrict transactions.

After sending out a blanket email earlier in the month, the response I got back was largely negative in that most had a mindset of, 'the TSP is a long term investment that shouldn't be traded.'

There are two questions I have for the TSP board, 1) how can a person excessively trade, if they are only abiding by the rules the TSP board established? 2) What is the real motivation behind restricting transactions to two a month?

 

[Show-me]

Can anyone tell me how to reach the ETAC military rep at the Pentagon? Need an office or a phone number?

Colonel Adrienne Fraser-Darling, USMC,
ETAC Representative
Military Assistant, Office of the Principal Deputy Under Secretary of Defense, Personnel and Readiness, US Dept of Defense
Job site: The Pentagon
Room 3E788
Washington, D.C. 20301
Tel: (703) 697-2121
FAX - (703) 697-8256
e-mail: adrienne.fraserdarling@osd.mil

 

[Art2007]

Can anyone tell me how to reach the ETAC military rep at the Pentagon? Need an office or a phone number?

 

[airlift]

Jones,

I adopted and sent your letter to:

mailtoavidlRostker@omb.eop.gov

 

[airlift]

Jones,

What a beautiful brain you have! We need to use all legal avenues to stop the injustice, to stop the arrogance of power, and to bring accountability into process. Keep up the good work.

 

[namor]

I haven't paid much attention of late, but if it is a fact, that in the several month interim until the 2 trades per month rule is finalized, we must make our IFT's by mail, then shouldn't we all just trade everyday (by mail) until the 2 per month rule goes into effect? I would just do it to make their lives miserable. 1% into I; 1% out of I, 1% into I, etc. etc.

If you choose to use this method of fighting back (which is an EXCELLENT idea btw) be sure to change your preferences to receive your TSP confirmation IN THE MAIL. Only seems fair. . . if you want us to MAIL in our transfers, then TSP should have to MAIL back the confirmation.

You want to see costs skyrocket? Just think, TSP administration will see a new fire to put out: how to get these darn employees to use email confirmations!

 

[Miss_Piggy]

 

[kam]

I haven't paid much attention of late, but if it is a fact, that in the several month interim until the 2 trades per month rule is finalized, we must make our IFT's by mail, then shouldn't we all just trade everyday (by mail) until the 2 per month rule goes into effect? I would just do it to make their lives miserable. 1% into I; 1% out of I, 1% into I, etc. etc.

 

[JonesH2O]

Jones-

Good find.

You are right. PRA does apply, since the new paperwork that potentially could be imposed by this interim rule COULD include making people fill out new forms by mail and sending them in. The TSP form 50, allocation by mail, is not on the TSP website. So it will have to be considered a "new form" for PRA purposes. And making it's use mandatory does invoke the PRA.

Great job.

Go get-em tiger!

Thanks! I know my letter is in legalese, but this is the way I am use to writing when addressing General Counsel. As you said, PRA does apply. We'll see if it makes some noise . . .

 

[James48843]

Jones-

Good find.

You are right. PRA does apply, since the new paperwork that potentially could be imposed by this interim rule COULD include making people fill out new forms by mail and sending them in. The TSP form 50, allocation by mail, is not on the TSP website. So it will have to be considered a "new form" for PRA purposes. And making it's use mandatory does invoke the PRA.

Great job.

Go get-em tiger!

 

[JonesH2O]

Thanks JonesH2O.
I like this letter. I'm a little confused by your last statement,
"The email address is one that is contained in all proposed rule actions published in the Federal Register from my office that have PRA issues."
Do you mean to say that this is an addressee that you sent this letter to because of your individual/professional relationship to and not relative to the rest of us? If I'm making myself clear - lol.

The email address (either DavidlRostker@omb.eop.gov or David_Rostker@omb.eop.gov will work) is one that is listed in all proposed rule actions for constituents to submit comments on PRA issues. Do a Google search on the email addresses and you will see what I am talking about. There have been actions from my office that have stopped because the Agency did not seek clearance from the Office of Management and Budget prior to publishing in the Federal Register. It's a long short, but I figured it couldn't hurt.

 

[Miss_Piggy]

Thanks JonesH2O.
I like this letter. I'm a little confused by your last statement,
"The email address is one that is contained in all proposed rule actions published in the Federal Register from my office that have PRA issues."
Do you mean to say that this is an addressee that you sent this letter to because of your individual/professional relationship to and not relative to the rest of us? If I'm making myself clear - lol.

 

[JonesH2O]

I just faxed and mailed the following. I borrowed some from folks who provided comments earlier in this thread (thank you) and added a few more of my own.

Dear Mr. Emswiler,

These comments refer to the Interim rule published in the Federal Register on December 27, 2007 (72 FR 73251).

ADMINISTRATIVE PROCEDURE ACT

Pursuant to 5 U.S.C. 553(b), a general notice of proposed rule making shall be published in the Federal Register. This subsection does not apply when the agency for good cause finds (and incorporates the finding and a brief statement of reasons therefore in the rules issued) that notice and public procedure thereon are impracticable, unnecessary, or contrary to the public interest. The reasons listed in the preamble of this action do not show good cause for an Interim rule or emergency action. Therefore, this action is not exempt from the requirements of the Administrative Procedure Act.

Pursuant to 5 U.S.C. 553(d)(3), after notice required by this section, the agency shall give interested persons an opportunity to participate in the rule making through submission of written data, views, or arguments with or without opportunity for oral presentation. After consideration of the relevant matter presented, the agency shall incorporate in the rules adopted a concise general statement of their basis and purpose. This action does not give the public an opportunity to participate in any future rule making; one that presents a public record of comments and agency responses that are submitted with this action.

REGULATORY FLEXIBILITY ACT

This action states in the Classification section: I certify that these regulations will not have a significant economic impact on a substantial number of small entities. They will affect only employees of the Federal Government. Employees of the Federal Government are not small businesses or small organizations, so they can be certified as not having a significant economic impact. However, retiree's of the Federal Government, former federal employees (who have chosen to keep their money in the TSP) and small business who provide investment counseling to TSP shareholders are small entities and small business entities under the Regulatory Flexibility Act. Therefore, this action will have a significant economic impact on those entities.

PAPERWORK REDUCTION ACT

This action states in the Classification section: I certify that these regulations do not require additional reporting under the criteria of the Paperwork Reduction Act. Pursuant to 5 CFR Ch. III Part 1320.3 Definitions - For the purposes of this definition of ‘‘ten or more persons,'' ‘‘persons'' does not include employees of the respondent acting within the scope of their employment, contractors engaged by a respondent for the purpose of complying with the collection of information, or current employees of the Federal government (including military reservists and members of the National Guard while on active duty) when acting within the scope of their employment. Therefore, retirees of the Federal Government and former federal employees, are not exempt from Paperwork Reduction Act.

Currently, § 1601.22 of the TSP regulations state participants may make an interfund transfer using the TSP Web site or the ThriftLine, or by completing and filing (mailing) the appropriate paper TSP form. The action would change the current voluntary method of requesting an interfund transfer, to a mandatory requirement to request interfund transfers by mail. Paperwork Reduction Act rules are clear on voluntary vs. mandatory requirements: Conversion from voluntary to mandatory information collection would be considered a substantive modification of the existing requirement, even though the number of responses and burden hours may not change. Therefore, this action is not exempt from the requirements of the Paperwork Reduction Act.

For the above reasons, I request that the Interim Rule be withdrawn. Thank you for the opportunity to comment on this action.

Sincerely,

I also just sent an email to DavidlRostker@omb.eop.gov with written comments regarding the burden-hour estimate and other aspects of the collection-of-information requirement contained in the Interim rule to the Office of Management and Budget (OMB). This Executive Office oversees the requirements of the Paperwork Reduction Act (PRA). The email address is one that is contained in all proposed rule actions published in the Federal Register from my office that have PRA issues.

 

[RAE]

Just how successful has the "fight" been up to this point? Has there been a consolidated thoughtful response to the Federal Register notice recently published?

TMC - a number of folks have responded to the Fed. Register notice with comments, as you can see from this thread. We won't be able to evaluate the "success" of this effort for some time, since it's a long fight, and this is just one step in the battle. If you are concerned about this issue, as many of us are, please send a letter, as it will certainly help. If you go back through this thread, you will see several examples of letters that can be drawn from, if you need to. Or, if you prefer to compose your own original letter, that's great too. The main thing is, please write! thanks.