What Total Cost Reporting still won't show you

The new rules are a big step. But several costs that matter most to larger portfolios are outside them, or only partly covered.

Not reported

One all-in rate for your account

The report shows fund costs in dollars and a percentage for each fund. It doesn't combine your advisory fee and fund costs into one rate for the whole account, the number most useful for comparison.

“What is my total all-in cost as a percentage of my portfolio, including fees inside my funds?”

Excluded

Private and pooled funds sold without a prospectus

Regulators excluded prospectus-exempt funds because of implementation issues and said they may extend the rules later. Larger portfolios often hold pooled or private funds, and their costs won't be added up for you. You'll only get a general notice that such products have embedded fees.

“Are any of my holdings prospectus-exempt or pooled funds? What do they cost each year, all-in?”

May get no report

Corporate, holding-company and trust accounts over $10 million

Under CIRO rules, the annual fee report is required for retail clients. A corporation, trust or other non-individual with more than $10 million in securities at a dealer can be classified as an institutional client, so these accounts may not receive the report at all.

“How is my corporate account classified? Will it receive the annual cost report?”

Not reported

Currency conversion spreads

Regulators don't treat foreign exchange spreads as a transaction charge, so they aren't reported. Firms are only encouraged to include a general notice. With large US-dollar holdings, the spread on every conversion adds up.

“What spread do you charge on currency conversions, and roughly how much did I pay last year?”

Excluded

Structured notes

Principal-protected and market-linked notes are outside the rules. Their embedded costs aren't quantified, only noted in general terms.

“What fees and dealer compensation are built into the notes I hold?”

Partly reported

Bond mark-ups

When a dealer buys or sells bonds for you, it can report its mark-ups in dollars, or report only commissions plus a general statement that remuneration was added to the price. A bond-heavy portfolio may never see a dollar figure.

“Do you report my bond mark-ups in dollars? What did I pay on bond trades last year?”

Notice only

Third-party fees

Custody, trustee and intermediary fees or interest paid to third parties aren't included in the totals. The report only has to say they may not be reported.

“Am I paying any custody, trustee or interest charges outside your fee?”

Optional

A benchmark for your returns

Your annual performance report doesn't have to compare your returns with a benchmark. You'll see what you paid, but not necessarily whether it bought better results.

“What benchmark should my portfolio be measured against, and how have I done after all fees?”

Start with your all-in rate

The one number the new report leaves out.

Check my all-in cost

Sources