I have been pursuing the Union angle with several emails, etc as I assume others have been. Our Union has a representative on the ETAC Board. We received the following letter from Coleen Kelley our NTEU President.
March 24, 2008
M E M O R A N D U M
TO: Chapter Presidents and Legislative Coordinators
RE: NTEU Comments on Thrift Board Regulations
SUMMARY: NTEU has submitted comments to the Federal Retirement Thrift Investment Board regarding its March 10 submission to the Federal Register proposing to amend the interfund transfer regulations to limit the number of interfund transfer requests to two per month.
On March 19, 2008, I sent the attached letter to the General Counsel at the Federal Retirement Thrift Investment Board, asking that the proposed regulations not be enacted. As I noted in my letter, the problems caused by those participants who were engaged in daily trading appears to have been greatly reduced by the actions of the Board so far. Numbers provided by the Board to the Employee Thrift Advisory Council members (ETAC), of which NTEU is a member, show that daily trades have been significantly reduced – the largest number in January was 40,000. The largest number in February was a little over 11,000.
I urged the Board to leave unrestricted the number of trades available per month, but to keep an eye on frequent trading so we can control it and put restrictions in when, and if, they become necessary. I suggested that, if restrictions do become necessary, a revised policy of two free trades per month coupled with a fee imposed on subsequent trades would be a more equitable solution. In addition, at any time participants could transfer to the G Fund at no charge.
If you have any questions on this subject, please call Cathy Ball in the Legislation Department at 202-572-5500, ext.8067.
Colleen M. Kelley
National President
Attachment
NTEU The National Treasury Employees Union
March 19,2008
Mr. Thomas K. Emswiler
General Counsel
Federal Retirement Thrift Investment Board
1250 H Street, N. W.
Washington, D.C. 20005
Dear Mr. Emswiler:
Please accept the following comments fiom the National Treasury Employees Union (NTEU) in
regard to the regulations published on March 10,2008, proposing to amend the interfund transfer
regulations to limit the number of interfund transfer requests to two per month.
NTEU continues to believe that while maintaining low costs for participants is critical, going from
the present unrestricted number of transfers to a restricted number of transfers is unnecessary at this time.
The Board itself states that the change will affect "a very small number of TSP participants" (see proposed
TSP solution in the regulations). Less Draconian methods adopted by the Board - letters to participants
and publicity about the costs of 3,000 participants trading frequently - has resulted in what appears to be
an almost 72 percent reduction in the amount of daily trades (letter to the Employee Thrift Advisory
Council, March 7,2008.) Those 547 participants who persist in "daily trading" and have chosen to ignore
the consequences of their actions are being dealt with already in a letter to be sent at the end of March.
I propose that we make no changes at this time. As was stated in the regulations, "the hallmark of
the TSP is simplicity." I agree. We should keep it simple. It seems to us that the problem has been greatly
reduced and may be completely resolved in the near future. If for some reason, the Board feels it is
necessary to act now to change the system, then NTEU proposes a revision to the Board's plan: allow two
transfers per month and after two transfers (if other than to the G Fund), attach a fee for servicing the
transfer. While it may be "impossib1e to correctly assign the exact costs," we can follow the leads of other
such funds in arriving at a figure. In addition, we would need to make
clear that at any time participants could transfer to the G Fund at no charge. We agree that the safe harbor
of the G Fund must always be available.
In conclusion, it appears that the Board has done its usual excellent work in addressing what could
have been a serious problem. Certainly it is prudent to watch this area, and if we find that frequent trading
harms the Fund in the future, we can talk about putting some restrictions in place. I do not think this action
is called for at the present time. ci ,&
Colleen M. Kelley
National President
cc: ETAC Members
1750 H Street, N.W. Washington, D.C. 20006 (202) 572-5500
While this response isn't perfect (i.e. with regard to the 547 being penalized unfairly) it appears to be a step in the right direction!