| Frequently
Asked Questions Regarding Late Trading Policies
November 26, 2003
The US mutual
funds (the "Funds") advised by Dimensional Fund Advisors Inc.
("Dimensional") issued a statement, dated September 15, 2003,
informing clients of the position of the Funds on certain issues
raised by regulators relating to market timing and late trading.
Since that time, we have received inquiries from certain of
our clients, most stemming from practices discussed in the media
relating to other mutual fund companies' activities. We have
prepared these FAQs to clarify our position with respect to
those practices.
| 1. |
Do
the Funds allow late trading or what is sometimes referred
to in the industry as market timing in the Funds?
No.
The Funds have not entered, and will not enter, into
any arrangements with any investors, financial intermediaries,
or any other third parties that permit late trading
or excessive short-term trading in any Funds. |
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| 2. |
What
is the Funds' trading policy?
As
discussed in the Funds' prospectuses, the Funds' policy
requires that orders received prior to 4:00 p.m. EST
be executed at that day's closing price. Orders received
after 4:00 p.m. EST are executed at the following day's
closing price. This policy also applies to investors
who place their orders through financial intermediaries,
such as retirement plan administrators. However, these
financial intermediaries are permitted to transmit their
customers' orders after 4:00 p.m. EST to the Funds,
provided the financial intermediaries had received the
orders from their customers before that time. |
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| 3. |
Have
the Funds communicated with financial intermediaries
about the Funds' policies on late trading and short-term
trading?
In
September, Dimensional, on behalf of the Funds, sent
letters to the financial intermediaries that are authorized
to transmit orders for the Funds' shares to the Funds
after 4:00 p.m. EST, requesting that the financial intermediaries
certify their compliance with the terms of the agreements
with the Funds, with applicable law, and with policies
and procedures designed to screen market timing and
late trading. Dimensional attorneys have closely reviewed
the responses received from the financial intermediaries,
to verify their compliance with applicable law and the
Funds' policies as stated in the Funds' prospectuses. |
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| 4. |
Why
do the Funds discourage short-term trading?
Short-term
trading, which may increase the number of trades in
the Funds, may disrupt the Funds' investment strategies
and increase the Funds' transaction costs. This, in
turn, may reduce the Funds' overall returns for long-term
investors. The Funds' prospectuses clearly state that
the Funds are not designed for short-term trading. |
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| 5. |
What
are the Funds' policies with respect to transactions
in shares of Funds by portfolio managers and officers?
All
portfolio managers and officers are required to report
quarterly all transactions in the Funds' shares. To
date, our review of such reported transactions does
not indicate that such employees engaged in market timing
or other short-term investment transactions to the detriment
of investors. In addition, this month we requested and
received certifications from all employees of Dimensional
that they have not engaged in any such transactions. |
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| 6. |
What
compliance processes are in place for the Funds?
Dimensional
has a compliance committee, headed by Dimensional's
Chief Financial Officer, which reviews matters relating
to compliance by the Funds, and reports to the Chief
Executive Officer of Dimensional. |
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| 7. |
Does
Dimensional manage hedge funds?
No,
Dimensional does not manage any hedge funds. |
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| 8. |
Are
the Funds sold with 12b-1 fees that are paid to brokers?
No,
the Funds are a no load fund family, and the Funds do
not pay 12b-1 fees to brokers. |
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| 9. |
Have
Dimensional or the Funds received a subpoena from any
state's attorney general relating to their mutual fund
activities?
Neither
Dimensional, nor the Funds, have been contacted by the
office of any state attorney general. |
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| 10. |
Are
Dimensional or the Funds under investigation by the
Securities and Exchange Commission?
The
SEC has not advised Dimensional or the Funds that they
are the subjects of any investigation.
The
Funds did receive two letters of inquiry from the SEC
in September, regarding the Funds' practices, and two
follow-up inquiries related to those initial letters.
We understand the first SEC letter was sent to the 80
largest fund companies, and requested information about
market timing, late trading, and distribution of portfolio
holdings information. We understand the second letter
was sent to mutual fund families with funds that invest
at least a majority of their assets in international securities,
and asked about the fair value pricing of those securities.
The Funds responded to the SEC's letters and will continue
to fully cooperate with all requests. To be clear, these
SEC requests for information in no way imply any wrongdoing
by the Funds or any other fund family. |
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| 11. |
Do
the Funds use fair value prices?
Consistent
with the 2001 letter from the SEC's Doug Scheidt, the
Boards of Directors/Trustees (the "Board") of the Funds
previously had approved a policy of fair value pricing
of the Funds' portfolio securities when a significant
event occurs, which the Funds have been following. More
recently, the Board has been considering the impact
of the correlation between foreign market securities
prices and domestic market securities price movements.
The Funds have retained a third-party pricing vendor
to assist in pricing the non-US equity securities owned
by the Funds, pursuant to the pricing procedures approved
by the Board. |
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| 12. |
How
many independent directors are on the Funds' Board?
Six
out of eight of the Funds' Board members are independent
directors. |
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