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Why Are ETFs (Sometimes) More Tax-Efficient Than Mutual Funds?

A reader writes in, asking:

“Could you provide an explanation of why ETFs are often said to be more tax efficient than mutual funds or index funds? I’ve read about it before but have never been able to follow.”

I’m happy to discuss this, but in order to understand the idea, we have to cover some background information first. Specifically, we have to discuss:

  • One basic concept about the tax treatment of funds, and
  • How shares of an ETF are created.

What Happens When a Fund Sells Something?

Whenever a fund (whether an ETF or traditional mutual fund) sells one of its holdings from the portfolio, if that holding is sold at a gain, shareholders of the fund have to pay tax on their share of that gain (if they hold the fund in a taxable brokerage account, that is).

How ETF Shares Are Created

When an investor buys shares of a traditional mutual fund, the transaction is a transaction between the investor and the mutual fund itself. The investor gives cash to the fund, and the fund creates new shares of the fund, which are given to the investor.

In contrast, when you or I buy shares of an ETF, we’re buying already-existing shares from some other shareholder who already owned those shares. So how do ETF shares get created in the first place?

The answer has to do with entities known as “authorized participants.” Authorized participants are generally super big financial entities (e.g., banks).

When a company that runs an ETF wants to create shares, it essentially does a swap with an authorized participant. It creates new shares of the ETF, and it gives those shares of the ETF to the authorized participant, in exchange for cash or a “basket” of securities (e.g., the 500 stocks in the S&P 500, if it’s an ETF that tracks the S&P 500). These swaps are usually done in very large dollar amounts (e.g., 50,000 shares of the ETF in exchange for the appropriate amount of other securities).

The ETF Tax Advantages

When an investor in a traditional mutual fund wants to sell his/her shares for cash, the transaction is again a transaction with the mutual fund itself. The fund needs to have cash on hand, so that it can pay that cash out to the shareholder redeeming the shares. And sometimes (depending on how many shares are being redeemed on any given day) raising that cash requires selling stuff. And as we discussed earlier, when a fund sells anything at a gain, shareholders in that fund have to pay tax on their share of that gain. In other words, when one shareholder sells his shares of the mutual fund, if the fund has to sell stuff at a gain in order to pay off that shareholder, that creates a tax cost that will be ultimately be paid by the remaining investors in the fund.

In contrast, if you or I want to sell shares of an ETF, that’s a transaction that happens on the secondary market. We aren’t transacting with the fund itself at all. We’re just selling our shares to somebody else who wants to buy them. And that means that the ETF doesn’t have to do anything — doesn’t have to sell anything, and no tax costs are incurred by remaining shareholders in the fund.

In addition, when an authorized participant wants to redeem shares of the ETF, the ETF basically does the share creation process (i.e., the swap described above), just in the opposite direction. This is known as a share redemption. In an ETF redemption, the ETF gives shares of investments to an authorized participant, and the authorized participant gives ETF shares back to the fund. And because this is an “in-kind” transaction, it’s not considered a taxable event. So the ETF is able to hand off those underlying investment shares without technically having sold them — no tax cost.

This is made even more tax-efficient by the fact that, when the ETF swaps out shares of any given company, it will naturally choose to give away the shares that have the lowest cost basis (i.e., keep the ones that have the highest cost basis, in case they have to be sold — thereby allowing any gains that have to be realized to be smaller gains).

So, in short, ETFs are often more tax-efficient than traditional mutual funds because they have a way of satisfying redemptions without having to actually sell anything and because they have a way of strategically unloading their shares of investments with the lowest cost basis (without generating a capital gain in the process).

Two Important Caveats

While the ETF structure does give it some tax advantages over a traditional mutual fund, there are two important caveats to keep in mind.

First caveat: the underlying portfolio and investment strategy of the fund still matters. It matters a lot. For instance:

  1. A fund (whether it’s an ETF or mutual fund) that follows a “total stock market” strategy is going to be much more tax-efficient than an actively managed stock fund that does a lot of buying and selling. Because, as discussed above, selling stuff at a gain results in tax costs to shareholders. So, higher portfolio turnover generally means worse tax-efficiency, and lower portfolio turnover generally means better tax-efficiency — regardless of whether the fund is an ETF or traditional mutual fund.
  2. A fund that pays a lot of fully-taxable ordinary income (e.g., a high-yield corporate bond fund) is simply not going to be very tax-efficient — and that’s true regardless of whether the fund is an ETF or traditional mutual fund.

Second caveat: this whole discussion largely does not apply to Vanguard ETFs as compared to Vanguard index funds. That’s because for many Vanguard funds, the ETF and index fund are literally the same fund. They’re just different share classes. So the share redemption process that ETFs can use (i.e., swapping out shares of holdings with low cost basis, to authorized participants) benefits the Vanguard index funds as well (as long as the index fund in question also has an ETF share class). In addition, the Vanguard patent on this “ETFs as a separate share class of an existing fund” idea recently expired (in May 2023). So it would not be at all surprising if other fund companies eventually implemented the same concept. (And many companies are already actively in the process of doing so.)

Why Invest in Index Funds?

The following is an adapted, excerpted chapter from my book Investing Made Simple: Investing in Index Funds Explained in 100 Pages or Less.

Pay less for a product or service, and you’ll have more money left over afterwards. Pretty straightforward, right? For some reason, many investors seem to think that this rule doesn’t apply to the field of investing. Big mistake.

Index Funds 101

A bit of background: Most mutual funds are run by people picking stocks or other investments that they think will earn above-average returns. Index funds, however, are passively managed. That is, they seek only to match (rather than beat) the performance of a given index.

For example, index funds could be used to track the performance of:

  • The entire U.S. stock market,
  • Certain sectors of the U.S. stock market (the pharmaceutical industry, for instance),
  • Various international stock markets,
  • The bond market of a given country, or
  • Just about anything else you can think of.

Most Actively Managed Funds Lose.

The goal of most actively managed funds is to earn a return greater than that of their respective indexes. For example, many actively managed U.S. stock funds seek to outperform the return of the U.S. stock market. After all, if an active fund doesn’t beat its index, then its investors would have been better off in an index fund that simply tracks the market’s return.

Interestingly, most investors actually would be better off in index funds. Why? Because — due to the high costs of active management — the majority of actively managed funds fail to outperform their respective indexes. In fact, according to a study done by Standard and Poors, for the ten-year period ending 6/30/2022:

  • Less than 9% of U.S. stock funds managed to outperform their respective indexes,
  • Less than 12% of international stock funds managed to outperform their respective indexes, and
  • Less than 27% of taxable bond funds managed to outperform their respective indexes.

Now, lest you think that this particular period was an anomaly, let me assure you: It wasn’t. Standard and Poors has been doing this study since 2002, and each of the studies has shown very similar results. Actively managed funds have failed in both up markets and down markets. They’ve failed in both domestic markets and international markets. And they’ve failed in both stock markets and bond markets.

Why Index Funds Win

The investments included in a given index are generally published openly, thereby making it easy for an index fund to track its respective index. All the fund has to do is buy all of the stocks (or other investments) that are included in the index.

When you compare such a strategy to the strategies followed by actively managed funds (which generally require an assortment of ongoing research and analysis, in order to try to buy and sell the right investments at the right times) you can see why index funds tend to have considerably lower costs than actively managed funds.

Common sense (and elementary school arithmetic) tells us that:

  • If the entire stock market earns, say, a 9% annual return over a given decade, and
  • The average dollar invested in the stock market incurs investment costs (such as brokerage commissions and mutual fund fees) of 1.1%,

…then the average dollar invested in the stock market over that year must have earned a net return of 7.9%.

Now, what if you had invested in an index fund that sought only to match the market’s return, while incurring minimal expenses of, say, 0.1%? You would have earned a return of 8.9%, and you would have come out well ahead of most other investors.

It’s counterintuitive to think that by not attempting to outperform the market, an investor can actually come out above average. But it’s completely true. The math is indisputable. John Bogle (the founder of Vanguard and the creator of the first index fund) referred to this phenomenon as “The Relentless Rules of Humble Arithmetic.”

Why Not Pick a Hot Fund?

Naturally, many investors are inclined to ask, “Why not invest in an actively managed fund that does beat its index?” In short: because it’s hard — far harder than most would guess — to predict ahead of time which actively managed funds will be the top performers.

In addition to their “indices versus active” scorecards, Standard and Poors also puts out “persistence scorecards” from time to time. In the most recent one (published November 2022), they found that of the funds that had a top-quartile ranking for the five years ending June 2017, only 21.46% maintained a top-quartile ranking for the following five-year period. Pure randomness would suggest a repeat rate of 25%. In other words, picking funds based on superior past performance was usually unsuccessful and proved to be slightly worse than picking randomly.

In another study, Morningstar’s Russel Kinnel looked at the usefulness of expense ratios and star ratings (which are based on past performance) at predicting future performance. Kinnel summarized his findings:

Investors should make expense ratios a primary test in fund selection. They are still the most dependable predictor of performance. […] Stars can be helpful, too, particularly in identifying funds that might be merged out of existence.

In other words, past performance can be useful for identifying future poor performers. (That is, the worst performing funds tend to continue to perform poorly, and they are often shut down by the fund company running them.) But if you’re looking to pick a future top performer, picking a low-cost fund is your best bet. And looking for low-cost funds naturally leads to the selection of index funds as likely top-performers.

Taxes Are Costs Too.

If you’re investing in a taxable account (as opposed to a 401(k) or IRA), index funds can help you not only to minimize costs, but to minimize taxes as well. With mutual funds, you pay taxes each year on your share of the capital gains realized within the fund’s portfolio.

Because most active fund managers buy and sell investments so rapidly, a large percentage of the gains end up being short-term capital gains. Because short-term capital gains are taxed at your ordinary income tax rate (as opposed to long-term capital gains, which are currently taxed at a maximum rate of 20%), you’ll end up paying more taxes with actively managed funds than you would with index funds, which typically hold their investments for longer periods of time.

Not All Index Funds Are Low-Cost.

Do not, however, invest in a fund simply because it’s an index fund. Some index funds actually charge expense ratios that are close to — or sometimes even above — those charged by actively managed funds. It’s a good idea to take the time to check a fund’s expense ratio and compare it to the expense ratios of other funds in the same category before investing in it.

When Index Funds Aren’t an Option

Unfortunately, in many investors’ primary retirement account — their 401(k) or 403(b) — they don’t have the option to select any low-cost index funds. If you find yourself in such a situation, my strategy for picking funds would be as follows:

  1. Determine your ideal overall asset allocation (that is, how much of your overall portfolio you want invested in U.S. stocks, how much in international stocks, and how much in bonds).
  2. Determine which of your fund options could be used for each piece of your asset allocation.
  3. Among those funds, choose the ones with the lowest expense ratios and the lowest portfolio turnover. (For funds in your 401(k) or 403(b) this information should be available in the plan documents.)

Simple Summary

  • Because of their low costs, index funds consistently outperform the majority of their actively managed competitors.
  • A fund’s past performance (even over extended periods) is not a reliable way to predict future performance.
  • Not all index funds are low-cost. Before investing in an index fund, take the time to compare its expense ratio to the expense ratios of other index funds in the same fund category.
  • If you don’t have access to low-cost index funds in your retirement plan at work, look for low-cost, low-turnover funds that fit your desired asset allocation.

Asset Allocation and Risk Tolerance

The following is an adapted excerpt from my book Investing Made Simple: Investing in Index Funds Explained in 100 Pages or Less.

When putting together a portfolio, the first thing to decide is your desired asset allocation. That is, how much of your portfolio should be invested in each asset class (e.g., U.S. stocks, international stocks, and bonds)?

Your tolerance for risk is the most important factor in determining an appropriate asset allocation. The primary factors determining your risk tolerance are:

  1. Your economic/financial ability to tolerate risk (i.e., how much risk you can afford), and
  2. Your emotional/psychological ability to tolerate risk.

Your economic ability to handle risk is significantly impacted by the degree of flexibility you have with regard to your financial goals.

Financial Flexibility

Example 1: Jason is a construction worker. He’s 57, and each day he is becoming increasingly aware that his body is unlikely to be able to continue in his line of work for more than two or three more years. Between his Social Security and savings, Jason is pretty sure that his basic expenses will be covered — but only barely. Because Jason can neither delay his retirement nor reduce his expenses, Jason has a low ability to take risk.

Example 2: Debbie is 54. She hopes to retire at 62 with enough savings to provide for $80,000 of annual spending. Debbie likes her work though, so she wouldn’t terribly mind having to work until her late 60s. And $80,000 is just a goal. She knows she could get by just fine with about 70% of that. Because Debbie’s goals are flexible, she has a greater ability to take risk.

Comfort with Volatility

Your risk tolerance is also affected by your comfort level with volatility. One way to estimate this comfort level is to ask yourself, “How far could my portfolio fall before I started losing sleep, feeling stressed, or wanting to sell everything and move to cash?”

When answering this question, be sure to answer both as a percentage and as a dollar value — otherwise you may come to inaccurate conclusions. For example, you may remember that at age 25 you experienced a 40% loss and handled it just fine. But if you’re 45 now, and your portfolio is 10-times the size that it was at age 25, a 40% loss could be an entirely different experience.

When assessing your risk tolerance, it’s generally wise to guess conservatively. If you end up with a portfolio that’s slightly too conservative for your tastes, you’ll only be missing out on a relatively small incremental return.

In contrast, if you end up with a portfolio that’s too aggressive, you might end up panicking during periods of high volatility. Even one instance of getting out of the market after a sharp decline can be more than enough to eliminate the extra return you were hoping to earn from having a stock-heavy allocation.

Stocks vs. Bonds

Once you have an idea of your risk tolerance level, it’s time to move on to the first (and most important) part of the asset allocation decision: your stock/bond allocation.

One rule of thumb that serves as a reasonable starting point for analysis is to consider limiting your stock allocation to the maximum tolerable loss that you determined above, times two. Or, said differently, assume that your stocks can lose 50% of their value at any time.

The most important thing to remember with asset allocation guidelines, however, is that they’re just that: guidelines. For example, with regard to this particular rule of thumb, it’s important to understand that a loss greater than 50% certainly could occur, despite the fact that such declines are historically uncommon. This is especially true if your stock holdings are not well diversified or if your non-stock holdings are high-risk such that they could decline significantly in value at the same time that your stocks do.

U.S. Stocks vs. International Stocks

As you might imagine, the U.S. stock market isn’t the best performing market in the world every single year.

The difficulty in international investing — as with picking stocks or actively managed mutual funds — is that it’s nearly impossible to know ahead of time which countries are going to have the best market performance over a given time period. The solution? Own all (or at least many) of them.

The primary goal of investing a portion of your portfolio internationally should not be to increase returns, as there is no guarantee that international markets will outperform our own. Rather, the primary goal is to increase the diversification of your portfolio, thereby reducing your risk.

In total, the U.S. stock market makes up roughly half of the value of all of the publicly traded stocks in the world. (It varies over time, depending on how the U.S. market has performed recently relative to other markets.) However, for two reasons, most investment professionals recommend allocating more than 50% of the stock portion of your portfolio to domestic equities. First, international funds generally have somewhat higher expense ratios than domestic funds. Second, investing internationally introduces an additional type of risk into your portfolio: currency risk.

Currency risk is the risk that your return from investing in international stocks will be reduced as a result of the U.S. dollar increasing in value relative to the value of the currencies of the countries in which you have invested.

EXAMPLE: A portion of your portfolio is invested in Japanese stocks, and over the next year it earns an annual return of 8%. However, over that same period, the value of the yen relative to the dollar decreases by 3%. Your annual return (as measured in dollars) would only be roughly 5%.

So how much of your portfolio should be invested internationally? There’s a great deal of debate on this issue, with investment professionals recommending a very wide range of international allocations.

Without knowing how the U.S. market will perform in comparison to markets abroad, there’s simply no way to know what the “best” allocation will be. As with most asset allocation decisions, there’s a pretty broad range that’s reasonable. Allocating anywhere from 20% to 40% of the stock portion of your portfolio to international index funds would be reasonable for most investors—with the general idea being to give international stocks a somewhat smaller weighting than their (roughly) 50% market weight (due to their higher costs and currency risk), while still making sure that the international allocation is of sufficient size for it to offer a meaningful diversification benefit.


No matter how perfectly you craft your portfolio, there’s little doubt that, in not too terribly long, your asset allocation will be out of whack. The stock market will have either shot upward, thereby causing your stock allocation to be higher than intended, or it will have experienced a downturn, causing your stock allocation to be lower than intended.

Rebalancing is the act of adjusting your holdings to bring them back in line with your ideal asset allocation. A periodic rebalancing program helps keep the risk level of your portfolio in line with your goals.

How often should an investor rebalance? That’s a tricky question. Some people advocate in favor of rebalancing once your portfolio is off balance by a certain amount (such as your stock allocation being either 10% higher or 10% lower than intended). Others argue that rebalancing should be done at regular intervals (annually on your birthday for instance) regardless of how off-balance your portfolio becomes in the interim.

The best-performing rebalancing strategy varies from period to period, and it’s no easy task to predict which one will do best over the course of your investing career. Rather than spending a great deal of time and effort thinking about it, my suggestion is simply to pick one method and resolve to stick with it.

It’s worth noting that rebalancing can be quite difficult emotionally/psychologically. It can feel as if you’re selling your “good investments” to put money into your “bad investments.” The key is to remember that just because something has performed well (or poorly) recently doesn’t mean that it will continue to do so in the immediate future.

Simple Summary

  • Your tolerance for risk should be the primary determinant of your stock/bond allocation. Your risk tolerance is determined by how much risk you can afford and how much risk you can tolerate psychologically.
  • Generally speaking, it’s better to have an asset allocation that’s too conservative than an asset allocation that’s too aggressive.
  • For the sake of additional diversification, most investment professionals recommend investing somewhere from 20% to 40% of your stock holdings internationally.
  • Rebalancing is the act of bringing your portfolio back to its targeted asset allocation (and, therefore, its targeted risk level).

The Cost (to an Index Fund) of Turnover in an Index

A reader writes in, asking:

“When stocks enter or leave an index, an index fund is forced to sell the leaving stocks and buy the entering ones. I have heard that this results in a cost to the index fund. Is this cost big enough to matter much?”

There are two types of costs imposed on an index fund when stocks move in or out of the index that the fund tracks: transaction costs and front-running costs.

Transaction costs are the brokerage costs and bid/ask spreads incurred by buying and selling shares of a stock.

Indexes themselves, unlike index funds, have no transaction costs. As such, transaction costs would show up in the form of “tracking error” (i.e., the amount by which an index fund trails the performance of its respective index). As it turns out though, most index funds from reputable providers (e.g., Vanguard, Fidelity) don’t often trail their indexes by amounts significantly more than their expense ratios. In other words, the total transaction costs for such funds are often sufficiently small that they typically don’t even make an observable impact on fund performance.

Given the above, and given that transaction costs from stocks entering/leaving the index are only a part of an index fund’s overall transaction costs, we can confidently conclude that the transaction costs specifically resulting from changes in the index must be very small.

The second type of costs, front-running costs, are the reduction in performance that results from other parties bidding up the price of a stock by buying shares after the announcement that the stock will be added to a given index but before index funds buy it. It’s difficult to estimate such costs because they don’t show up as tracking error, because such costs affect the performance of the index itself as well as the performance of index funds.

In the last decade, two studies estimated the cost of front-running to be in the 0.2-0.3% per year range for index funds that track the S&P 500. That would certainly be a significant cost over time. However, other parties have argued that the cost has likely declined (and will continue to decline) as front-running opportunities are largely eliminated due to the idea becoming so well known.

In addition, you’re largely unaffected by such costs if you stick to “total market” funds, because your fund would already hold such stocks well before the bidding up that happens when the stock is announced for inclusion in something like the S&P 500.

So in short, yes, costs are imposed on an index fund when stocks are added to or removed from the index that it tracks. However, such costs (both transaction costs and front-running costs) tend to be very small, especially for the most diversified index funds.

What’s the Maximum Expense Ratio Somebody Should Pay for a Mutual Fund?

A reader writes in, asking:

“As I try to select among the funds in my 401k plan, is there a limit to the high end of expense ratio that you suggest not going beyond?”

The maximum expense ratio that I would pay for a fund depends on the context. Specifically, it depends on the availability of a less expensive suitable substitute.

For example, consider an investor with a $100,000 portfolio, all of which is in her 401(k). She has decided that her ideal asset allocation would be:

  • 60% in US stocks,
  • 20% in international stocks, and
  • 20% in bonds.

And, in her 401(k), the lowest-cost investment options in each of those categories are:

  • A “total stock market” index fund with an expense ratio of 0.1%,
  • An actively managed international stock fund with an expense ratio of 0.7%, and
  • A “total bond market” index fund with an expense ratio of 0.1%.

Our investor has a dilemma. She wants a 20% international stock allocation in her portfolio. But she would have to pay an extra 0.6% per year for that part of the portfolio in order to have such an allocation (rather than just allocating the entire stock part of the portfolio to the US stock index fund).

Frankly, if I were in that position, I wouldn’t pay the additional cost. I appreciate international diversification, but an avoidable cost of 0.6% per year is a high hurdle for the diversification to overcome in terms of added value.

But what if our investor’s lowest-cost investment options were as follows?

  • An actively managed US stock fund, with an expense ratio of 0.65%,
  • An actively managed international stock fund with an expense ratio of 0.7%, and
  • A “total bond market” index fund with an expense ratio of 0.1%.

In this case, our hypothetical investor would now only be paying an additional 0.05% per year for her international allocation. The international fund’s cost hasn’t changed at all, but it has become quite a bit more attractive because the alternative (i.e., keeping the entire stock allocation in the US stock fund) has become more expensive.

Point being: The maximum expense ratio that it makes sense to pay depends on the cost and suitability of the nearest substitute. In our first scenario the 0.7% expense ratio was too high because there was a low-cost substitute (albeit an imperfect substitute). In the second scenario, the 0.7% expense ratio was not prohibitive, because there was no low-cost substitute.

What if There Are Multiple Accounts?

Let’s look at one more hypothetical scenario. Our investor still desires an allocation of 60% US stocks, 20% international stocks, and 20% bonds. And the options in her 401(k) are the same as in our first scenario above:

  • A “total stock market” index fund with an expense ratio of 0.1%,
  • An actively managed international stock fund with an expense ratio of 0.7%, and
  • A “total bond market” index fund with an expense ratio of 0.1%.

In this case, however, her portfolio consists of $50,000 in her 401(k) and $50,000 in a Vanguard IRA. In this case, she has no reason whatsoever to pay the high cost of the international fund in her 401(k), because she could achieve her desired overall allocation by buying an international index fund/ETF in her IRA.

Again, the overall conclusion is that the maximum “acceptable” expense ratio for a fund varies based on the availability of less expensive suitable substitutes.

Why Don’t Vanguard’s Target Retirement and LifeStrategy Funds Own Admiral Shares?

One question I receive periodically is why the Target Retirement and LifeStrategy funds at Vanguard hold “Investor” shares of the underlying funds, rather than the less expensive “Admiral” shares. Emily Farrell, Head of U.S. Business PR at Vanguard, was kind enough to provide the answer.


Piper: Why don’t the LifeStrategy and Target Retirement funds use Admiral shares as the underlying holdings?

Or, if there’s a concern about that being a way to “cheat” to get access to Admiral shares without meeting the requirements, why not have an Admiral share class for the LifeStrategy and Target Retirement Funds, with a higher minimum investment (i.e., a high enough figure such that a person investing that amount via an identical DIY allocation would qualify for Admiral shares of all or most of the underlying funds)?

Farrell: Vanguard is unable to offer multiple share classes on funds of funds due to the structure in which we operate, and the agreement we have with the SEC regarding multiple share classes. Our funds of funds have no direct costs — the costs are derived only from the ERs of the underlying funds. According to that agreement, we must be able to offer a differentiated cost advantage between share classes. (Therefore, because there is no direct cost associated with a fund of fund — it’s not possible for us to offer such an advantage).

As you may recall, we launched a suite of Institutional TRFs in 2015. Note, however, those are not share classes — they are an entirely new set of mutual funds.

Piper: Given that Vanguard can only have one share class of a fund-of-funds, how does Vanguard decide which share classes to hold within such funds? The “normal” (non-institutional) versions of the funds-of-funds each hold Investor shares of the underlying funds. Would Vanguard ever consider holding Admiral share classes in these funds?

And, for example, the Vanguard Institutional Target Retirement 2050 Fund (VTRLX) holds Institutional shares of one underlying fund, Admiral shares of another fund, and Investor shares of two funds. What’s the line of thinking there?

Farrell: It is largely based on the cost to serve the underlying shareholder of the TRF or LifeStrategy Fund. These funds tend to attract small balance accounts and IRAs, and the cost to serve is disproportionately higher than funds with large and diverse shareholders. In terms of looking into adding holding Admiral in the Investor suite of TRFs, in short, the answer is yes — we consistently review our products, product structures, and product line-ups. However, given the size of the average TRF account and our cost allocation methodologies, we would not expect a change from Investor Shares. Specific to the underlying holdings of the Institutional suite of TRFs, again, it is cost to service the funds and our cost allocation methodologies that dictate the share class utilized.


So, to paraphrase, Vanguard’s position here is, “in a Target Retirement or LifeStrategy fund, we hold whichever share class (or share classes) result in an expense ratio that most closely reflects the cost to service the fund’s shareholders.” In hindsight, that feels sort of obvious, given Vanguard’s general “at cost” pricing philosophy.

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