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While I enjoy Ms. Morgenson's columns and generally agree with them, they nevertheless tend to resemble hit pieces with the occasional questionable statement or two. Never factually wrong, but laden with innuendo.
She decries the "often hefty costs associated with TIAA funds". Yet elsewhere in the article she she states that "the average asset-weighted expense ratio on TIAA’s mutual funds was 0.32 percent in 2016", and acknowledges that this was "lower than the 0.57 percent mutual fund industry average".
She attempts some jiujitsu by arguing that this is still too high (though not calling the fees "hefty" in this section). Here's how she does that: : "Although lower than the 0.57 percent mutual fund industry average, it is more expensive than a low-cost provider like Vanguard, whose average expense ratio was 0.11 percent in 2016."
She gives M* as her data source. Here's what M* had to say:
The asset-weighted average fee of Vanguard’s funds fell to 0.11% from 0.14% during the past three years [2013-2016]. This 21% decline was the largest percentage decline among the largest fund providers, thanks to large flows into Vanguard’s low-priced ETFs and index funds and falling fees in some of Vanguard’s largest funds as the fund company passes improving efficiencies to fundholders. During that period, Vanguard has strengthened its leading position, as its market share rose to 22% from 18%. Vanguard’s 2016 asset-weighted average expense ratio of 0.11% was significantly below that of the second-lowest-cost provider, SPDR State Street, at 0.19%, followed by Dimensional Fund Advisors at 0.36%.
What we glean from this is that (a) you need to look at active/passive mix before chastising a family for high fees or lauding it for low ones, and (b) TIAA's 0.32% is right in line with other low cost families. Is Vanguard the only family that advisors are now allowed to use? Who are these other low cost providers that are like Vanguard?
That's not to say TIAA may not have been taken some dubious actions. Likely enough to take some of the shine off its white knight image. But ISTM not enough (or at least not enough documented) to paint it as an especially bad actor.
The one complaint she linked to seems to have merit IMHO. We have to take her word on the whistle-blower complaint though, since it is currently confidential. We don't know what else is in it, just as we didn't know the additional M* data that I gave above. (Yup, there's my own innuendo, without AFAIK misstating facts.)
To repeat, I like Ms. Morgenson's columns, I think she does a great job at digging through the underside of the financial world. But I don't take them (or any columnist piece) as gospel.
According to internal and S.E.C. documents, TIAA advisers receive more money if they put clients into what the company calls complexity products — in-house offerings like annuities and life insurance as well as costlier private asset management accounts and fee-based Portfolio Advisor accounts.
This creates an incentive, former employees said, for sales representatives to push retiring professors or administrators to move money from their institutional plan, with annual costs of around 0.3 percent of assets under management, to managed accounts charging fees of 0.7 percent to 1 percent.
To put this in perspective, the new DOL regs for fiduciaries allow different levels of compensation for selling different categories of products, up to a certain level.
BICE allows higher compensation for selling complex products that require more work to explain to the customers. (DOL FAQ: "variation [in commission] is permitted ... based on neutral factors, such as the time and complexity associated with recommending investments".) This arises from the reasonable compensation rule.
At the same time, BICE forbids the additional compensation to be so high as to create an incentive to push these products. More generally (again from DOL FAQ) "financial institutions cannot 'use or rely upon quotas, appraisals, performance or personnel actions, bonuses, contests, special awards, differential compensation or other actions or incentives that are intended or would reasonably be expected to cause Advisers to make recommendations that are not in the Best Interest of the Retirement Investor.'"
If it takes someone twice as much time and effort to sell product A as product B, and compensation is equal, that person has a disincentive to sell (or "push", as Ms. Morgenson wrote) product A. That is true regardless of how much more or less profitable one product or the other is for the company. Unequal compensation for different products can be reasonable. Whether the differences merely equalize the sales incentives for different products or bias them (presumably toward the more profitable product) is a matter of the magnitude of the differences in compensation.
According to the DOL, the mere existence of compensation differences does not automatically create an incentive to sell one over the other, Ms. Morgenson aside. Yet she leaps immediately to the conclusion that it must, with no numbers, no explanation.
The TIAA Form ADV Part 2A that she cited mirrors the DOL regs: "TIAA’s compensation philosophy aims to reward Advisors with appropriate compensation, recognizing the degree of effort generally required of the Advisor in gathering and retaining client assets in appropriate TIAA accounts, products and services offered by TIAA affiliates."
Ms. Morgenson also leaps from writing about "advisers" in the first paragraph (who are bound by fiduciary duty, BICE, etc. not to be incentivized to "push" higher profit products) to "sales representatives" in the second paragraph, who are under no such constraints. Which one is it? Is the undisclosed complaint talking about sales reps or advisers?
That matters because, as I stated before, while this doesn't help TIAA's reputation, it doesn't paint them as an exceptionally bad actor. I've written before about Fidelity's reps having similar compensation schedules. Here's Fidelity's 2017 Introduction to Representatives’ Compensation.
"Certain representatives also receive differing compensation for different product types, for example, managed account and insurance product sales, which require more in-depth engagement with clients, provide more compensation than products such as money market funds." For example, Fidelity reps get quarterly compensation of 1 basis point for investments in MMFs, while10 basis points for investments in Fidelity's Portfolio Advisory Services and/or insurance products.
For anyone who's suggested going to a brokerage to discuss ideas "for free", tell me again how great a bargain that is.
Comments
She decries the "often hefty costs associated with TIAA funds". Yet elsewhere in the article she she states that "the average asset-weighted expense ratio on TIAA’s mutual funds was 0.32 percent in 2016", and acknowledges that this was "lower than the 0.57 percent mutual fund industry average".
She attempts some jiujitsu by arguing that this is still too high (though not calling the fees "hefty" in this section). Here's how she does that:
:
"Although lower than the 0.57 percent mutual fund industry average, it is more expensive than a low-cost provider like Vanguard, whose average expense ratio was 0.11 percent in 2016."
She gives M* as her data source. Here's what M* had to say: What we glean from this is that (a) you need to look at active/passive mix before chastising a family for high fees or lauding it for low ones, and (b) TIAA's 0.32% is right in line with other low cost families. Is Vanguard the only family that advisors are now allowed to use? Who are these other low cost providers that are like Vanguard?
That's not to say TIAA may not have been taken some dubious actions. Likely enough to take some of the shine off its white knight image. But ISTM not enough (or at least not enough documented) to paint it as an especially bad actor.
The one complaint she linked to seems to have merit IMHO. We have to take her word on the whistle-blower complaint though, since it is currently confidential. We don't know what else is in it, just as we didn't know the additional M* data that I gave above. (Yup, there's my own innuendo, without AFAIK misstating facts.)
To repeat, I like Ms. Morgenson's columns, I think she does a great job at digging through the underside of the financial world. But I don't take them (or any columnist piece) as gospel.
BICE allows higher compensation for selling complex products that require more work to explain to the customers. (DOL FAQ: "variation [in commission] is permitted ... based on neutral factors, such as the time and complexity associated with recommending investments".) This arises from the reasonable compensation rule.
At the same time, BICE forbids the additional compensation to be so high as to create an incentive to push these products. More generally (again from DOL FAQ) "financial institutions cannot 'use or rely upon quotas, appraisals, performance or personnel actions, bonuses, contests, special awards, differential compensation or other actions or incentives that are intended or would reasonably be expected to cause Advisers to make recommendations that are not in the Best Interest of the Retirement Investor.'"
If it takes someone twice as much time and effort to sell product A as product B, and compensation is equal, that person has a disincentive to sell (or "push", as Ms. Morgenson wrote) product A. That is true regardless of how much more or less profitable one product or the other is for the company. Unequal compensation for different products can be reasonable. Whether the differences merely equalize the sales incentives for different products or bias them (presumably toward the more profitable product) is a matter of the magnitude of the differences in compensation.
According to the DOL, the mere existence of compensation differences does not automatically create an incentive to sell one over the other, Ms. Morgenson aside. Yet she leaps immediately to the conclusion that it must, with no numbers, no explanation.
The TIAA Form ADV Part 2A that she cited mirrors the DOL regs: "TIAA’s compensation philosophy aims to reward Advisors with appropriate compensation, recognizing the degree of effort generally required of the Advisor in gathering and retaining client assets in appropriate TIAA accounts, products and services offered by TIAA affiliates."
Ms. Morgenson also leaps from writing about "advisers" in the first paragraph (who are bound by fiduciary duty, BICE, etc. not to be incentivized to "push" higher profit products) to "sales representatives" in the second paragraph, who are under no such constraints. Which one is it? Is the undisclosed complaint talking about sales reps or advisers?
That matters because, as I stated before, while this doesn't help TIAA's reputation, it doesn't paint them as an exceptionally bad actor. I've written before about Fidelity's reps having similar compensation schedules. Here's Fidelity's 2017 Introduction to Representatives’ Compensation.
"Certain representatives also receive differing compensation for different product types, for example, managed account and insurance product sales, which require more in-depth engagement with clients, provide more compensation than products such as money market funds." For example, Fidelity reps get quarterly compensation of 1 basis point for investments in MMFs, while10 basis points for investments in Fidelity's Portfolio Advisory Services and/or insurance products.
For anyone who's suggested going to a brokerage to discuss ideas "for free", tell me again how great a bargain that is.