July 30, 2010
Your proposal is wonderful for individual investors BUT NOT for institutional investors.
Keep in mind that 403(b) plans are required to use either insurance products or mutual funds. Limiting the ability of mutual funds to pay plan administrative expenses or for education/communication may push these plans to MORE expensive annuity products.
My recommendations are:
For INDIVIDUAL investors -- implement your proposal
For INSTITUTIONAL investors -- develop a new arrangement that may include the following:
-- Not more than 3 institutional share classes
-- The most expensive institutional share class would be limited to total annual fees equal to or less than A shares with the front-end load waived
-- The fund company would notify the INSTITUTIONAL investor whenever the minimum requirements were satisfied to move to a share class with lower annual expenses