Cross-Trading by ERISA Plan Managers Final Report Thomas H. McInish, Ph.D., C.F.A. Tel: 901-678-4662 Fax: 901-678-3006 Email:
[email protected] Cross-Trading by ERISA Plan Managers Executive Summary ERISA prohibits cross trades, the exchange of assets between two accounts without going through a public market. There have been numerous exemption requests motivated by a desire to reduce transaction costs. Mutual funds are permitted to cross trade under Rule 17a-7. Opportunities for cross trades arise when some funds within a group have cash inflows and others have cash outflows and due to differences of opinion among managers for a given mutual fund group about the desirability of holding particular assets. Cross trades represent an economically significant source of savings for mutual funds. With a view toward identifying insights relevant to cross-trading, this study reviews the academic literature dealing with the way financial markets are organized and how this organization affects transaction costs, dealer quotes and prices, and other market characteristics. Transaction costs include direct costs such as commissions and indirect costs such as the bid-ask spread, which covers order processing costs (the normal expenses of providing liquidity) and asymmetric information costs (dealer losses to informed traders). Additional indirect costs are market impact costs, delay costs, and the opportunity costs of missing a trade. Transaction costs typically range from one to four percent, depending on a number of factors such as the type of asset (equities, debt, derivatives, and currencies), daily trading volume in the asset, the size of the order, market conditions (recent news, whether others are buying or selling), and the country in which the asset is traded.