Kudos to Fidelity for Lowering Index Fees.

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Kudos to Fidelity for Lowering Index Fees.

Postby 92irish » Tue Dec 11, 2012 12:37 pm

Everytime I think about consolidating everything to Vanguard....they do this. I specially like the fact that "Advangtage" shares can be had for just $10K in assets. Merry Christmas from Fidelity.

http://pymnts.com/news/businesswire-fee ... 1211006094[url][/url]

Edit: Title for spelling.
Last edited by 92irish on Tue Dec 11, 2012 4:00 pm, edited 1 time in total.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby runner9 » Tue Dec 11, 2012 12:43 pm

Not really relevant, but I like how the article is dated today, 3:30pm and we're reading it before noon on the east coast.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Sunny Sarkar » Tue Dec 11, 2012 12:57 pm

I'll stay with Vanguard because I do not believe that Fidelity have their heart in it - i.e. they are lowering fees only in a desperate attempt to stop the flow of fee conscious dollars to Vanguard, not for the sake of the investors' returns.
“Our life is frittered away by detail. Simplify, simplify.” ― Henry David Thoreau
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Re: Kudso to Jack Bogle for Lowering Index Fees.

Postby Taylor Larimore » Tue Dec 11, 2012 12:58 pm

92irish wrote:Everytime I think about consolidating everything to Vanguard....they do this. I specially like the fact that "Advangtage" shares can be had for just $10K in assets. Merry Christmas from Fidelity.

http://pymnts.com/news/businesswire-fee ... 1211006094[url][/url]

92Irish:

This is indeed good news for Fidelity investors.

In my opinion, the general lowering of Expense Ratios by virtually all fund companies (for competitive reasons) can be traced back to Jack Bogle who offered the first index fund for ordinary investors.

Our mentor was more interested in lowering costs for investors than enriching himself.

A pebble in a pond starts an ever-widening ripple effect.

Thank you, Jack
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Grt2bOutdoors » Tue Dec 11, 2012 1:02 pm

I'm an equal opportunist when it comes to reducing expenses. Let the cuts begin. :beer
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby ruralavalon » Tue Dec 11, 2012 1:06 pm

Probably a direct consequence of Vanguard reducing the minimum investment for Admiral class shares of its index funds to $10k.

Competition over expenses is great :) .
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Sunny Sarkar » Tue Dec 11, 2012 1:06 pm

Mutual fund companies across the industry have been grabbing headlines with announcements of lower-cost products. Is Vanguard engaged in a fee war?
Mr. McNabb: No, not at all. Vanguard has been lowering the cost of investing for more than 35 years. The mere fact that we exist puts pressure on other providers to do likewise. In the end, that benefits investors broadly.

Here's a quick story: A few years ago, when we announced our intention to begin providing mutual funds to investors in the United Kingdom, a British investment firm lowered their fees in anticipation of our arrival. We took it as a compliment. Members of the financial press called it the "Vanguard effect."

So despite the claims of some, we feel strongly that running an investment firm at-cost—where we provide the services it takes to run the funds and support our clients for the same cost we pay to do it—is a great thing for all investors. And you, as loyal clients, should know that we don't think our work is finished.

We'll continue to seek ways to save you even more money. Not just for certain products or services, or for selected clients, or for a limited time. We aim to lower the cost of investing for all of our clients, across all of our funds and services. That's our enduring pledge to you.

What does Vanguard's client ownership structure mean for investors?
Mr. McNabb: Vanguard's client ownership structure is the most important thing to understand about our company. Everything follows from our structure. Vanguard is owned by our funds, and our clients—our shareholders—own our funds. Being owned by our clients brings an amazing level of clarity to every decision we make. It means that everything that we do has to pass this test: Is it in the best interest of our clients? That's the filter we use when we consider offering a new service, or take a position on a regulatory matter, or launch a new fund, or think about ways to lower the cost of investing.

Serving our clients—and only our clients—makes us unique. For example, we never have to decide between passing along lower costs to our clients and announcing higher quarterly earnings to stakeholders. Our clients are our only stakeholders.

We are client-first by design. In this business, it's a radically simple idea.

https://personal.vanguard.com/us/insigh ... ebt-112012
“Our life is frittered away by detail. Simplify, simplify.” ― Henry David Thoreau
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Tim_in_GA » Tue Dec 11, 2012 1:11 pm

92irish wrote:Everytime I think about consolidating everything to Vanguard....they do this. I specially like the fact that "Advangtage" shares can be had for just $10K in assets. Merry Christmas from Fidelity.


Nice - thanks for posting that! I have my Roth IRA with them and I can now use the Advantage Class funds.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby STC » Tue Dec 11, 2012 2:04 pm

This is a very big deal for me. My Roth and my ESPP - and as a result 1 of my 2 taxable accounts - are both at Fidelity. Their Total Stock Market and Total International both now have competitive rates. So I can, over time, shift my core to Fidelity and use my TD Ameritrade free ETF's to get my Small Cap (VBR, VSS) and emerging markets (VWO) exposure. I was considering opening a Vanguard account, then going through the tedious process of moving my ESPP contributions each month. Now I wont have to do that. YAY!!!
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby ObliviousInvestor » Tue Dec 11, 2012 2:05 pm

Lowering the minimums from $10,000 to $2,500 is also great news for new investors.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby gatorking » Tue Dec 11, 2012 2:27 pm

Probably a result of moving from Boston, MA to Smithfield, RI :)
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Rainier » Tue Dec 11, 2012 2:32 pm

ObliviousInvestor wrote:Lowering the minimums from $10,000 to $2,500 is also great news for new investors.


Is that effective immediately or 1/1/13?

This will allow some of my smaller asset classes to move out of ETFs into the Spartan funds, just one more level of simplicity in my Fidelity accounts.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Snow Boarder » Tue Dec 11, 2012 2:49 pm

Like them or not Fidelity Advantage Class now have ERs and Investment Minimums not comparable but exactly equal to Vanguards Admiral Class.

I looked up in the Fidelity prospectus the ERs for Rick Ferri's Core Four Portfolio. They are identical.
0.06 Total Stockmarket
0.18 Total International Stockmarket
0.10 Total Bond Market
0.10 REIT Index

The advantage class reduced its minimum from $100k down to $10k to equal Vanguards.

Fidelity is competitive - If you use their Spartan Index funds...
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Boglenaut » Tue Dec 11, 2012 2:52 pm

This is great news. I have some funds there that I was considering moving to VG. The main reason not to was simply because I don't like being out of the market during the move (adds risk market goes up while out). The main reason to do it was a very small difference in ER and just simple house-cleaning for simplicity. Now it looks like the reason to move just decreased, so Fidelity will keep me longer as a happy customer. :sharebeer
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby TSR » Tue Dec 11, 2012 3:00 pm

Great news. If I truly don't have to lift a finger to have all of my investor-class shares converted to advantage-class, I'll be damn impressed.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby retiredjg » Tue Dec 11, 2012 3:06 pm

It is getting easier and easier to suggest using or staying at Fido. I think this is great!
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby STC » Tue Dec 11, 2012 3:13 pm

Boglenaut wrote:This is great news. I have some funds there that I was considering moving to VG. The main reason not to was simply because I don't like being out of the market during the move (adds risk market goes up while out). The main reason to do it was a very small difference in ER and just simple house-cleaning for simplicity. Now it looks like the reason to move just decreased, so Fidelity will keep me longer as a happy customer. :sharebeer



You dont have to be out of the market during a transfer. If you call up Vanguard, they will set you up with a concierge who can give you the proper paperwork for something called an "in-kind" transfer. I validated that this just moves what you already own, without being out of the market for even a second. Look into it if you are still interested.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Boglenaut » Tue Dec 11, 2012 3:19 pm

I don't see anything if these are permanent or waivers....
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby jon-nyc » Tue Dec 11, 2012 3:20 pm

Not sure what Kudso is but, hey, kudos to Fidelity all the same! :P
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby bikenfool » Tue Dec 11, 2012 3:50 pm

jon-nyc wrote:Not sure what Kudso is but, hey, kudos to Fidelity all the same! :P

I think Kudso is weed taking over Florida isn't it? : :wink:
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby KyleAAA » Tue Dec 11, 2012 3:52 pm

Sunny Sarkar wrote:I'll stay with Vanguard because I do not believe that Fidelity have their heart in it - i.e. they are lowering fees only in a desperate attempt to stop the flow of fee conscious dollars to Vanguard, not for the sake of the investors' returns.


Why do their motivations matter?
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby umfundi » Tue Dec 11, 2012 4:04 pm

KyleAAA wrote:
Sunny Sarkar wrote:I'll stay with Vanguard because I do not believe that Fidelity have their heart in it - i.e. they are lowering fees only in a desperate attempt to stop the flow of fee conscious dollars to Vanguard, not for the sake of the investors' returns.


Why do their motivations matter?

Yes,

At Bogleheads 11 the skepticism was that other companies would compete with Vanguard but do not have the inherent advantage that Vanguard has. Think: Loss leader.

But, for those now paying lower fees at other companies, who really cares why?

Keith
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby ObliviousInvestor » Tue Dec 11, 2012 4:11 pm

Rainier wrote:
ObliviousInvestor wrote:Lowering the minimums from $10,000 to $2,500 is also great news for new investors.


Is that effective immediately or 1/1/13?

This will allow some of my smaller asset classes to move out of ETFs into the Spartan funds, just one more level of simplicity in my Fidelity accounts.

Looks like it's effective immediately, at least upon a spot check of their Total Market, U.S. Bond, and International index funds:

http://fundresearch.fidelity.com/mutual ... /315911404
http://fundresearch.fidelity.com/mutual ... /315911107
http://fundresearch.fidelity.com/mutual ... /315911602
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Khanmots » Tue Dec 11, 2012 4:16 pm

umfundi wrote:
KyleAAA wrote:
Sunny Sarkar wrote:I'll stay with Vanguard because I do not believe that Fidelity have their heart in it - i.e. they are lowering fees only in a desperate attempt to stop the flow of fee conscious dollars to Vanguard, not for the sake of the investors' returns.


Why do their motivations matter?

Yes,

At Bogleheads 11 the skepticism was that other companies would compete with Vanguard but do not have the inherent advantage that Vanguard has. Think: Loss leader.

But, for those now paying lower fees at other companies, who really cares why?


I care because some of my investments are in taxable accounts and don't want to be in a position 10 years down the road where I have significant capital gains and Fidelity or whoever decides to raise their ERs. At that point I'd be stuck paying out. Either paying the higher ER, or paying significant capital gains taxes in order to move away from the money grab.

So part of my fund company analysis is what the relative odds are that they'll raise fees in the future (as part of a money grab, not a legitimate, our costs *really* did go up!). Given the difference in ownership structures I figure Vanguard is least likely of doing so.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Boglenaut » Tue Dec 11, 2012 4:25 pm

Khanmots wrote:
I care because some of my investments are in taxable accounts and don't want to be in a position 10 years down the road where I have significant capital gains and Fidelity or whoever decides to raise their ERs. At that point I'd be stuck paying out. Either paying the higher ER, or paying significant capital gains taxes in order to move away from the money grab.



In actuality, you've got it backwards. Historically, Fidelity kept the low fees and (I assume) took a loss when markets crashed a few years ago. Vanguard raises the ER's much more readily because they must do it at cost.

The trick with Fidelity to see if it is a waiver or not. Even if it is a waiver, they tend to keep them for very long periods of time. During the crash my TSM at VG had gone up from (I think) .09% to .18% while at Fidelity they stayed at .10% for investor class.

I think in the long run VG cost will be the best or very close to it. But if the asset value declines, they can spike ERs very quickly.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby umfundi » Tue Dec 11, 2012 4:29 pm

Khanmots wrote: I care because some of my investments are in taxable accounts ...


In the end, it may come down to that. Last year I moved all our taxable accounts to Vanguard from another fund company. Paid A LOT of taxes. Now, it's done.

Simplification.

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Re: Kudso to Fidelity for Lowering Index Fees.

Postby harikaried » Tue Dec 11, 2012 4:36 pm

Rainier wrote:Is that effective immediately or 1/1/13?
It seems that minimums are reduced effective today while expense ratios will be lowered 1/1/13. Fidelity's email also notes:

"For clients who will now qualify for the Fidelity Advantage® share class, the funds will automatically convert to the appropriate share class during our monthly updating process in January."
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby Random Musings » Tue Dec 11, 2012 5:11 pm

If it works for your situation, use it.

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Re: Kudos to Fidelity for Lowering Index Fees.

Postby SpringMan » Tue Dec 11, 2012 5:20 pm

According to my spreadsheet, which I kept up to date with Fidelity's website, the ER of FSIIX (EAFE index) was .11% after reductions and caps. It now shows .2% because reductions and caps are gone. The advantage class, FSIVX is .12% after reductions and caps. Does not sound like a reduction to me. The other Spartan Advantage class funds do seem a little better or the same. The new 10K minimums are a definitely a big improvement.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby centrifuge41 » Tue Dec 11, 2012 5:49 pm

If capital gains in FSIIX aren't too bad, maybe it's time to move over to global Spartan ex-US fund!
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby am » Tue Dec 11, 2012 6:41 pm

Does Fidelity have asset levels for which you get more services like Flagship at Vanguard?
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby Rainier » Tue Dec 11, 2012 6:49 pm

am wrote:Does Fidelity have asset levels for which you get more services like Flagship at Vanguard?


Yes, but I don't know what they are b
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby EyeDee » Tue Dec 11, 2012 8:54 pm

Boglenaut wrote:
Khanmots wrote:
I care because some of my investments are in taxable accounts and don't want to be in a position 10 years down the road where I have significant capital gains and Fidelity or whoever decides to raise their ERs. At that point I'd be stuck paying out. Either paying the higher ER, or paying significant capital gains taxes in order to move away from the money grab.



In actuality, you've got it backwards. Historically, Fidelity kept the low fees and (I assume) took a loss when markets crashed a few years ago. Vanguard raises the ER's much more readily because they must do it at cost.

The trick with Fidelity to see if it is a waiver or not. Even if it is a waiver, they tend to keep them for very long periods of time. During the crash my TSM at VG had gone up from (I think) .09% to .18% while at Fidelity they stayed at .10% for investor class.

I think in the long run VG cost will be the best or very close to it. But if the asset value declines, they can spike ERs very quickly.
.
Although I believe your explanation is correct, your numbers might be a little off.

In reviewing old annual reports, I found that the TSM Admiral expense ratios listed in the June 2008 and December 2008 to be .07, then went up to .09 according to the June 2009 and December 2009 reports but was back down to .07 in the June 2010 reports if I am reading things correctly.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby sunspotzsz » Tue Dec 11, 2012 9:04 pm

I hope they would lower the expenses for four in one funds.

We have all our IRAs in ffnox.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby tainted-meat » Tue Dec 11, 2012 9:37 pm

sunspotzsz wrote:I hope they would lower the expenses for four in one funds.

We have all our IRAs in ffnox.


I'm hoping for the same thing as well with my IRA as it is also in FFNOX. A great fund regardless.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby vachica » Tue Dec 11, 2012 9:38 pm

Woohoo! Now I have no reason to transfer my Roth to Vanguard. Their Freedom funds are weak and FFNOX is bond heavy, so I haven't had a balanced portfolio in my Roth. Now I will- and with lower fees. :sharebeer
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Khanmots » Tue Dec 11, 2012 9:46 pm

EyeDee wrote:
Boglenaut wrote:
Khanmots wrote:
I care because some of my investments are in taxable accounts and don't want to be in a position 10 years down the road where I have significant capital gains and Fidelity or whoever decides to raise their ERs. At that point I'd be stuck paying out. Either paying the higher ER, or paying significant capital gains taxes in order to move away from the money grab.



In actuality, you've got it backwards. Historically, Fidelity kept the low fees and (I assume) took a loss when markets crashed a few years ago. Vanguard raises the ER's much more readily because they must do it at cost.

The trick with Fidelity to see if it is a waiver or not. Even if it is a waiver, they tend to keep them for very long periods of time. During the crash my TSM at VG had gone up from (I think) .09% to .18% while at Fidelity they stayed at .10% for investor class.

I think in the long run VG cost will be the best or very close to it. But if the asset value declines, they can spike ERs very quickly.
.
Although I believe your explanation is correct, your numbers might be a little off.

In reviewing old annual reports, I found that the TSM Admiral expense ratios listed in the June 2008 and December 2008 to be .07, then went up to .09 according to the June 2009 and December 2009 reports but was back down to .07 in the June 2010 reports if I am reading things correctly.


That's not the point.

The point is that Vanguards costs are indexed to actuals and their ownership structure is such that they have no incentive to run with high actuals.

Other companies with different ownership structures have reason to charge you more. Some seem to take great glee in doing so... see RYSYX as an example. If the only reason that a companies fund is competitive in price is because they've decided that's the approach to take to maximize profits, nothing says that they can't decide that there's a different way to maximize profits in the future. I'd rather not risk it.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Sunny Sarkar » Tue Dec 11, 2012 10:31 pm

KyleAAA wrote:
Sunny Sarkar wrote:I'll stay with Vanguard because I do not believe that Fidelity have their heart in it - i.e. they are lowering fees only in a desperate attempt to stop the flow of fee conscious dollars to Vanguard, not for the sake of the investors' returns.

Why do their motivations matter?

It matters because they might change their minds after a few/several years, stop "discount"-ing the ER, and an investor in a taxable account will now be stuck between a rock (tax) and a hard place (higher fees). Not that big a deal in tax deferred accounts.

Another issue is that if they do not have their heart in it, they are unlikely to put as much energy into execution of the index funds like Vanguard does. No "Gus Sauter premium" for spartan fund investors maybe :happy
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby sunspotzsz » Tue Dec 11, 2012 10:51 pm

vachica wrote:Woohoo! Now I have no reason to transfer my Roth to Vanguard. Their Freedom funds are weak and FFNOX is bond heavy, so I haven't had a balanced portfolio in my Roth. Now I will- and with lower fees. :sharebeer



there is really no reason to transfer to vanguard.

if you are looking at expenses, schwab has lower expenses, with td ameritrade, you can buy vanguard etf for free, fidelity has the best credit card and debit card. vanguard doesn't have all the perks others have
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby stlutz » Tue Dec 11, 2012 10:56 pm

Does Fidelity have asset levels for which you get more services like Flagship at Vanguard?


What services are you looking for? Certainly in terms of banking services, Fidelity is much better--for everyone. If you're after free trades, Fido doesn't offer those like VG does to Flagship customers. I would guess you could also get a free cookie-cutter financial plan from Fido as well.

At the end of the day, where you hold your investments nowadays doesn't matter much anymore. You can setup a low cost indexed portfolio at VG, Fido, Schwab, TD Ameritrade etc. Let's also remember that lot of VG changes recently have been driven by competition as well. I agree with those who say that competition is our friend more than trust in the altruism of one organization over another.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby scrabbler1 » Wed Dec 12, 2012 1:09 am

I have a large holding in one of the Fidelity funds which is lowering its ER so I appreciate that reduction. Every little bit is nice.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby ProfessorX » Wed Dec 12, 2012 9:22 am

Gotta wonder what is the difference long term between a 0.10% ER and a 0.07% ER? The 0.03% difference seems like noise in comparison to something like say the "tracking error" which is inevitable.
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Re: Kudso to Fidelity for Lowering Index Fees.

Postby Boglenaut » Sat Jan 19, 2013 10:10 pm

Boglenaut wrote: The trick with Fidelity to see if it is a waiver or not.


I see info on Fidelity's page now that answers my question. For Spartan Total Market Index Fund - Fidelity Advantage Class(FSTVX):

    Expense Ratio: as of 01/01/2013 0.07%
    Expense Ratio after Reductions: as of 08/31/2012 0.07%
    Expense Cap: as of 01/01/2013 0.06%
    Expense Cap is a limit that Fidelity has placed on the level of the expenses borne by the fund until 04/30/2014 and indicates the maximum level of expenses (with certain exceptions) that the fund would be paying until that time. After the expiration date, the Expense Cap may be terminated or revised, which may lower the fund's yield and return.

So that's the bad news -- that it is not a permanant change. But Fidelity does have a history of extending these waivers.

All the same, I am still happy. Two of my funds benefitted from the new $10K limit and I like the ER reduction. It's enough to stop me from moving some funds to Vanguard as I had planned (but not enough to add to the positions). I won't lose sleep over .01%..
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby rj49 » Sun Jan 20, 2013 12:20 am

Fidelity can use the lower index fund expenses as a loss leader, to get people into their company and then push higher-cost products. I went with my sister to visit one of their financial advisors to invest an inherited IRA, and he gave her a fancy printout of a suggested asset allocation consisting entirely of high-priced managed funds, all with expense ratios over 1%. If I hadn't been there she probably would have gone for it, and perhaps signed up to the managed account they were also pushing. Instead I drew up a moderate asset allocation using only index funds and she made the advisor switch to those funds. The same works with other places, like Edward Jones and Schwab, where unsophisticated or scared investors trust an advisor (salesperson) who steers them into products with high returns for the company, including annuities.

I can see the appeal, though, for frightened retirees looking for safety and assurance, after the wild rides of the last decade and the unpromising current investment situation, especially for fixed income. But as Mr. Bogle says, they are croupiers out for their cut of the money, working for companies interested in making large profits, and one way is to get future loyal customers drawn by low expenses for the few of their mutual funds that are indexed. But that's not unique--that's why Amazon gives free shipping and Prime Membership, cell phone companies give away low-cost cell phones, and Costco sells cheap milk but makes you walk past all the shiny huge TVs and other temptations to get to it.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby nedsaid » Sun Jan 20, 2013 1:56 am

I am very glad that Fidelity is doing this. There are at least two large fund complexes where one can buy cheap index funds. The competition is good.

In my 403b, I have owned the Fidelity Spartan Total Market Index for years and was glad to be converted to the Advantage shares from the Investor shares. Seven basis points for a total market index is hard to beat.
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Re: Kudos to Fidelity for Lowering Index Fees.

Postby Boglenaut » Sun Jan 20, 2013 6:42 pm

nedsaid wrote:I am very glad that Fidelity is doing this. There are at least two large fund complexes where one can buy cheap index funds. The competition is good.

In my 403b, I have owned the Fidelity Spartan Total Market Index for years and was glad to be converted to the Advantage shares from the Investor shares. Seven basis points for a total market index is hard to beat.


See my post above. With the expense cap it's 6 basis points at least for 15 months (probably much longer).
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