Mutual Fund Fees and Expenses

1. Mutual Fund Fees and Expenses Chapter 4

2. Mutual Fund Fees and Expenses • The fees and expenses paid by mutual fund investors take multiple forms. Some charges are deducted from the fund’s value in clear view of the investor. For other charges, the amount is disclosed yet they are deducted out of the investors’ sight. The magnitude of certain charges is essentially invisible to fund investors. • The total monetary costs paid by mutual fund investors include front-end and deferred loads, operating expenses, account fees, and trading costs.

3. The expense ratio consists of management fees, Rule 12b-1 fees, and “other” expenses. “Other” expenses may include transfer agent fees, securities custodian fees, shareholder accounting expenses, legal fees, auditor fees, and independent director fees. Some of the account fees investors bear can include switching fees, redemption fees, and account maintenance fees. Trading costs include brokerage fees, bid–ask spreads, and market impact costs. • The purpose of this chapter is to describe the various fee and expense categories associated with mutual funds and their consequences for investors.

4. LOADS • Mutual fund loads come in two main forms: front-end loads and deferred loads. Front-end loads are paid when the investor initially buys shares of the fund. Deferred loads, also known as contingent deferred sales loads or back-end sales charges, are paid when the investor sells shares of the fund. Analysis of the Morningstar Principia database (2008) as of December 2007 reveals that just under 20 percent of U.S. mutual funds charged a front-end load, and just under 30 percent of U.S. mutual funds charged a deferred load. About 0.3 percent of funds had both.

5. Almost 52 percent of open-end mutual funds in the United States were “no-load funds,” meaning they did not charge loads of any kind. • For mutual funds with loads, the load levels are disclosed to investors as a percent of the fund’s net asset value. For example, the Fidelity Advisor Small-Cap Fund’s class A shares have a front-end load charge of 5.75 percent. An investor who writes a check for $10,000 to buy these class A shares will experience an immediate $575 reduction in his account balance as a result of the front-end load.

7. Although the load itself is 5.75 percent, a return of 6.10 percent would be required to restore the investor’s $10,000 wealth starting from the new $9,425 account balance. • Exhibit 4.1 shows that among mutual funds with front-end loads, over half charge loads of 1 percent or less. Of funds with deferred loads, over half charge loads above 4 percent. Mutual fund companies typically use the revenue from front-end loads to compensate brokers and financial advisers for helping to arrange the investor’s purchase of mutual fund shares.

8. The Financial Industry Regulatory Authority (FINRA) allows front-end loads to be a maximum of 8.5 percent. As of December 2007, only five U.S. mutual funds charged 8.5 percent. Even so, not all investors will have to pay the published load percentage. Funds customarily offer concessions when investors are willing to commit large amounts. Investment levels that trigger decreases in loads are known as breakpoints. Exhibit 4.2 shows that in the case of the Fidelity Advisor Small-Cap fund’s class A shares, breakpoints occur at $50,000, $100,000, and other levels, potentially resulting in dramatically reduced front-end loads.

10. According to the Investment Company Institute (ICI), the organization that represents the mutual fund and exchange-traded fund (ETF) industry, front-end loads weighted by mutual fund assets averaged 5.6 percent in 1980 and fell to 1.2 percent in 2007. The ICI attributes this decline to the dramatic increase in popularity of low-cost mutual funds in employer-sponsored retirement plans.

11. According to Morey (2003) the explosion of fund classes in the mid-1990s was accompanied by a brief resurgence in the proportion of funds with loads. • Deferred loads have not enjoyed the same dramatic decline as front-end loads. Morey (2002) shows that between 1992 and 2001, the percent of U.S. diversified equity mutual funds with deferred loads more than tripled, to above 30 percent. Barber et al. (2005) suggest that investors have become more alert about the costs of investing and particularly savvy about avoiding up-front fees. They speculate that mutual funds have responded by increasing expense ratios and deferred loads.

12. Chordia (1996) argues that investor redemptions of mutual funds impose costs on fellow investors. He then implies that by imposing a deferred load, a mutual fund can create—or perhaps attract—more patient investors. Thus, the fund will have less need to maintain high cash balances to service redemptions and will be relatively unaffected by cash drag (see Hill and Cheong, 1996). Morey (2002) notes that if investors are patient, the fund should also be able to invest in less liquid securities that have higher expected returns.

13. Examining the composition of deferred load funds, Morey finds that in the period after 1995, these funds do not maintain lower cash balances or invest in less liquid stocks than do no-load funds. He concludes that on average, any advantage of the deferred-load structure is not being exploited by managers. Another key disadvantage is that deferred-load funds tend to have much higher expense ratios than either front-end load or no-load funds.

14. Investors find it particularly costly to sell deferred-load mutual fund shares soon after investing. Typically, the magnitude of a deferred load decreases steadily throughout the investor’s holding period. If the investor waits a few years, the load can go to zero. Exhibit 4.3 shows that in the case of the Eaton Vance Large-Cap Value fund’s class B shares, the load amount declines by 1 percent per year after the fund has been held for two years. After eight years, the shares convert to A (front-load) shares, which have a much lower expense ratio than the B-class shares.

16. The decreased prevalence of front-end loads, even for retail class funds, is likely due to mounting evidence of underperformance by load funds relative to no-load funds. Contrary to the results of most researchers, Hooks (1996) reports that load equity mutual funds significantly outperformed no-load funds in the 15 years ending June 1993. Morey (2003) examines the out-of-sample performance f equity funds from 1993 to 1997. Using four performance measures and adjusting for load amount, he finds that no-load funds dramatically outperform funds that have either a front-end or a deferred load.

17. Surprisingly, according to two of the performance measures, no-load funds slightly outperform load funds even before loads are subtracted. The mere presence of a load, rather than its amount, appears to be the more important performance determinant. Morey joins Dellva and Olson (1998) in counseling investors interested in maximizing performance to avoid load funds. For investors who do not have performance maximization as the primary objective, they recommend using load funds only if the service advantage over no-load funds clearly warrants it.

18. EXPENSES • A mutual fund’s expense ratio reflects the amount required to cover the recurring costs of operating the fund. Expenses have both fixed and variable components. The largest component is the management fee that compensates the portfolio manager. For small mutual funds, the management fee is usually a specified percent of the assets under management, and it can be viewed by investors as a variable cost. For larger funds, the fee tends to be fixed, according to Gao and Livingston (2008).

19. In the case of funds of funds, including some target date and life cycle funds, investors can face two layers of expenses. The first layer is for the individual mutual funds held by the fund of funds. The second layer contains a management fee for the fund of funds itself. Some funds of funds waive the second layer of fees for investors. One example is Vanguard’s STAR fund, which owns 11 diverse Vanguard mutual funds. The STAR fund passes through the expenses from its own holdings but does not charge its own management fee.

20. Published expense ratios are equal to the mutual fund’s annual operating expenses divided by average daily assets. Expenses are typically charged to investors on a daily basis. Thus, for a fund that charges an annual expense ratio of 1.5 percent, the net asset value would decrease by 1.5 percent times 1/365 at the start of each day. • Exhibit 4.4 contains summary information on U.S. mutual funds as of December 2007. The simple (i.e., arithmetic or equally weighted) average expense ratio for U.S. common stock mutual funds is 1.34 percent. If expenses are weighted by assets under management, the average falls to 0.79 percent.

21. The simple and weighted averages for corporate/general bond funds are 1.13 percent and 0.71 percent, respectively. The lowest expense ratios are found among money market funds, followed by bond funds and then common stock funds. • Institutional class mutual funds have consistently lower expense ratios than retail class funds. For actively managed funds, the difference in annual expenses between the institutional and retail classes is about 40 basis points for all but money market and U.S. Treasury bond funds. For index funds, the difference ranges between 10 and 20 basis points.

23. Expenses of equity mutual funds vary widely. Haslem, Baker, and Smith (2008, 2009) show that about one-third of all actively managed institutional and retail equity mutual funds in the United States have expense ratios more than 1 standard deviation from the mean. Although this is expected for any normally distributed variable, 1 standard deviation is economically large: 33 basis points for institutional funds and 46 for retail funds. More than 5 percent of all funds’ expense ratios are more than 2 standard deviations above or below the mean.

24. The difference between ±2 standard deviations in expense ratio is 1.84 percent. Thus, two funds with identical returns gross of expenses yet expense ratios four standard deviations apart will have a 20 percent disparity in portfolio values after a 10-year holding period. • How have expenses changed over time? Average expense ratios in the U.S. mutual fund industry varied between about 0.5 and 1.5 percent over the past 50 years, depending on how they are measured.

25. As Barber et al. (2005) show, for U.S. diversified equity mutual funds, the asset-weighted expense ratio in the late 1960s fluctuated between 0.5 percent and 0.6 percent, and rose steadily toward 1 percent in the early 1990s. Exhibit 4.5 contains a graph of ICI (2008) data for the period since 1993, which indicates that expense ratios have declined in recent years. The simple average expense ratio rose from 1.43 percent in 1993 to 1.64 percent in 2002, and fell to 1.46 percent in 2007. The asset-weighted average expense ratio fluctuated around 1 percent until 2004, when it began falling and reached 0.86 percent in 2007.

27. Empirical tests have found that the path to better performance is paved with low-cost funds. For equity mutual funds, Dellva and Olson (1998) find a strong negative relation between expenses and four mutual fund performance measures. They reach this conclusion while holding constant for fund size, load, cash holding, beta, dividend yield, and turnover. Haslem et al. (2008) show the frequency with which actively managed equity mutual funds outperform the relevant Russell indexes, by expense ratio class.

28. Although only one-third to one-half of all funds outperformed the benchmark indexes over 1- to 15-year periods, less than one-quarter of mutual funds outperformed when they had expenses 1 or more standard deviations above the mean for their categories. • Wermers (2000) examines the actual holdings of actively managed mutual funds and finds that the chosen stocks outperform benchmark indexes by 1.3 percent per year from1975 to 1994. However, considering the expense ratio, transaction costs, and cash drag, Wermers finds these factors sufficient to explain the typical 1 percent net-of-fees underperformance of actively managed funds.

29. Thus, equity mutual fund managers are good stock pickers on average, but the expense ratio and portfolio turnover costs often prove an insurmountable hurdle to beating a passive approach. The Wermers study contains some of the more optimistic conclusions in the literature about the value of active mutual fund management. Even given these results, it is hard to justify recommending high-expense-ratio funds to investors who have the alternative of obtaining exposure to a market sector through low-cost index funds.

30. MANAGEMENT FEES • As noted in Haslem, Baker, and Smith (2007), a 1970 amendment to the Investment Company Act of 1940 states that independent directors have a fiduciary duty with respect to the reasonableness of mutual fund fees. Independent directors are not to approve increases in management fees, even with shareholder approval, if the increases provide no shareholder benefit.

31. Further, a majority of independent directors must approve any changes in advisory contracts, and they are “under duty” to request all information that is reasonably necessary to evaluate those contracts. • In his 2004 chairman’s letter to Berkshire Hathaway shareholders, Warren Buffett expresses his views about the role of mutual fund boards and management fees

32. Haslem et al. (2008, 2009) show that typical management fees for actively managed U.S. institutional and retail equity funds are between 75 and 80 basis points per year. For both institutional and retail funds, they find that the managers of mutual funds that outperformed their relevant Russell benchmark indexes over 1-, 5-, 10-, and 15-year periods currently receive higher management fees than their underperforming peer managers.

33. A related but rarely used type of structure is an incentive fee. According to Elton, Gruber, and Blake (2003), only 1.7 percent of mutual funds (that hold 10.5 percent of aggregate assets) employ incentive fees. Such fees are intended to encourage portfolio managers to outperform the funds’ benchmark indexes. Incentive fees have fixed and variable components, with the variable component providing a symmetric reward and penalty around the benchmark’s performance. Elton et al. find that mutual funds with incentive fees tend not to have to make reward payouts, because manager performance rarely merits such a payment.

34. Funds with incentive fees do outperform matched funds without such fees. The authors caution that this may be due to the motivational effects of the structure, or because superior managerial talent is drawn to funds that have incentive plans. Elton et al. also report that incentive fees appear to increase the risk-taking behavior of portfolio managers.

35. RULE 12B-1 FEES • Rule 12b-1 fees are among the most controversial in the mutual fund world. The fees, paid by current investors, are permitted under Rule 12b-1 of the Investment Company Act of 1940. Proceeds received from 12b-1 fees are intended as compensation for financial advisers and for marketing and advertising.

36. Such fees were designed to provide incentives for financial advisers to promote growth in fund assets through new flows from their clients. With the fund’s management and other fees spread over a larger number of dollars, the expense ratio should decline, providing a benefit to existing investors as well. According to the ICI (2007), 32 percent of stock mutual funds, 35 percent of bond mutual funds, and 15 percent of money market mutual funds charge 12b-1 fees.

37. How effectively do 12b-1 plans achieve their stated objectives of growing assets and decreasing fees to preexisting investors? Neither Trzcinka and Zweig (1990) nor Chance and Ferris (1991) find a relation between the existence of 12b-1 plans and mutual fund asset growth. In contrast, Barber et al. (2005) find a strong positive relation for 1993 to 1999, and Walsh (2004) confirms this for 1998 to 2002. Thus, the more recent research supports the notion that mutual funds with 12b-1 fees have higher growth than funds without such fees. The next question is whether fund shareholders derive benefit from the increased portfolio size.

38. Walsh (2004) examines this question and finds that the overall expense ratio decreases as fund size increases, but 12b-1 fees are very sticky. The size of the expense ratio decrease is not nearly as large as the magnitude of the unchanging 12b-1 fee. Moreover, the gross returns of 12b-1 funds are no higher than the returns for non-12b-1 funds, and some evidence suggests they are lower. This confirms in principle Malhotra and McLeod’s (1997) earlier result for returns net of expenses. Walsh concludes: “These results highlight the significance of the conflict of interest that 12b-1 plans create. Fund advisers use shareholder money to pay for asset growth from which the adviser is the primary beneficiary through the collection of higher fees” (p. 18).

39. Although the original intent of Rule 12b-1 was to promote a fund’s asset base and give existing fund shareholders access to lower expenses due to economies of scale, fund companies themselves do not tend to spend distribution fee revenue on advertising. The ICI (2005) surveyed its members in 2004, finding that 52 percent of fees are spent on shareholder services (with over 90 percent of this going to broker-dealers and bank trust departments); 40 percent are spent to pay financial advisers for initially directing the fund shareholder to the fund (with two-thirds as reimbursement of advance compensation received from an underwriter and one-third as ongoing compensation); 6 percent are paid to fund underwriters; and 2 percent of funds are spent for advertising.

40. Given that 12b-1 fees are intended to induce growth in fund size through new investment, investors should expect that closed funds will not levy 12b-1 fees. Surprisingly, many closed funds do. Consider Exhibit 4.6, which shows that according to Morningstar Principia as of December 31, 2007, 116 mutual funds listed as closed had a 12b-1 fee. Of these, 102 funds were closed to new investors only. Fourteen funds were closed to all investors, with three each offered by DWS Scudder, Hartford, and Oppenheimer.

41. As the rightmost column of Exhibit 4.6 indicates, the estimated total revenue from 12b-1 fees paid by investors of closed funds in 2007 is over $300 million. Of this, about $10 million is paid by fund shareholders who are not permitted to invest further in their own funds. First Eagle funds generated by far the highest estimated total 12b-1 fees, $48 million, with Julius Baer, Lord Abbett, and Van Kampen each having more than $20 million.

45. “OTHER” EXPENSES WITHIN THE EXPENSE RATIO • This catchall component of expenses can include transfer agent fees, securities custodian fees, shareholder accounting expenses, legal fees, auditor fees, and independent director fees. Transfer agent fees are paid to the entity that conducts crucial back-office functions, such as fund shareholder record keeping, calculation of interest, dividends, and capital gains, and the mailing of account and tax statements to fund shareholders.

46. The custodian is responsible for keeping the mutual fund securities safeguarded and partitioned from other assets. Major banks frequently serve in this role. Accounting expenses relate to the mutual fund’s internal record keeping. Auditor fees are paid to an external party that reviews the company’s books. As for legal fees, funds require professional assistance in preparing disclosure documents and negotiating investment advisory agreements with the fund’s portfolio manager, among other matters.

47. Independent director fees are paid to the fund’s trustees for serving on the board and on board committees. As Birdthistle (2006) notes, in many cases all the mutual funds for a particular adviser have the same board members, which means that the fees for board members can be spread over multiple funds and all those funds’ shareholders. While having the same board members for multiple funds can create efficiencies, it also raises potential governance issues.

48. LOAD VERSUS EXPENSE RELATION • Livingston and O’Neal (1998) advocate that mutual fund investors take a holistic approach to evaluating fund charges. They point out that the proliferation of fund classes over the past 15 years has created a confusing mix of loads and distribution fees. This presents a challenge to investors who want to evaluate the relative merits of gaining access to a portfolio via the various classes.

49. Livingston and O’Neil examine the virtues and drawbacks of three archetypical fund class structures: Class A shares have a front-end load of 5.75 percent and a 0.25 percent annual distribution (Rule 12b-1) fee; Class B shares have a 5 percent deferred load that decreases to 0 percent after eight years, plus a 1 percent annual distribution fee that decreases to 0.25 percent after eight years; Class C shares have a 1 percent deferred load that decreases to 0 percent after one year, plus a perpetual annual distribution fee of 1 percent.

50. Assuming an annual return of 10 percent and reinvestment of dividends, Livingston and O’Neal show that the Class C shares have the lowest cost if the investment is held for up to eight years, while the Class A shares have the lowest cost for holding periods greater than eight years. • In a later study, Hougeand Wellman (2007) observe that the explosion of share classes continues. They note a particular increase in new classes of funds that have much higher total fees than the funds’ preexisting classes.