ICMA-RC's Frequent Trading Policy

Frequent Trading Hurts Long-term Retirement Investors

Mutual funds available within retirement plans are intended for long-term investment purposes. While the vast majority of investors understand this principle, a handful of investors may engage in frequent or excessive trading. Unfortunately, the practices of a few can sometimes have an adverse affect on the majority of investors.

When mutual funds receive funds to invest in the stock or bond market, trading fees and commissions are generated. Similarly, when mutual funds have to generate funds to fulfill redemption requests, trading fees and commissions are also generated. As investors engage in frequent trading, these additional costs are shared equally among all investors in the mutual fund, including those not involved in the trading activity.

Furthermore, the rate of return long-term investors realize from investing in mutual funds may be impacted by frequent trading. Mutual funds may have to hold additional "uninvested" cash reserves in order to meet higher than normal redemptions, which reduces the earning potential of the fund.

Curbing Frequent Trading

The Securities and Exchange Commission and state law enforcement authorities are placing more emphasis on the effective enforcement of mutual fund policies. Particular focus is being paid to maintaining procedures to prevent or limit trading in mutual fund shares that is determined to be contrary to the interests of all fund shareholders.

ICMA-RC is committed to curbing frequent trading to protect long-term investors and is actively involved in enforcing mutual fund companies' policies designed to detect and prevent such frequent trading. Mutual fund companies may limit the ability to offer their funds in retirement plans if frequent trading guidelines are not properly enforced.

ICMA-RC Frequent Trading Policies

ICMA-RC defines frequent trading as a buy followed by a sell three times in the same fund during a 90 calendar day period or a buy followed by a sell 10 times in the same fund during a 365 calendar day period. Standard participant withdrawals, contributions, and distributions are not included in the policy. In addition, some mutual fund companies define frequent trading differently, and ICMA-RC reserves the right to enforce those guidelines.

Some funds, such as the Vantagepoint International and the Vantagepoint Overseas Index Funds, have additional measures to discourage frequent trading. For these two funds, investors who transfer assets out of them must wait at least 91 days before transferring assets back into the same fund.

If frequent trading and/or market timing activity is detected in a participant account, ICMA-RC may communicate with investors either over the phone or in writing about their trading activities in an effort to deter such activities. If such communications fail to deter the frequent trading activity, further action may be taken on the account such as restricting future purchases in the account.

ICMA-RC's aim is to monitor and enforce this frequent trading policy consistently. We cannot guarantee that all the risks associated with frequent trading will be completely eliminated by this policy and/or restrictions. If frequent trading goes undetected, the effect of such activity may result in additional transaction costs and dilution of long-term performance returns to such Funds. We reserve the right to update this policy at any time.

For more information on the frequent trading policy and for a complete summary of all fees, expenses, charges, financial highlights, investment objectives, risks and performance information, please consult both the current Vantagepoint Funds prospectus and MAKING SOUND INVESTMENT DECISIONS: A Retirement Investment Guide. The fund prospectus contains this and other information about the investment company and should be read carefully before investing any money. Vantagepoint securities are distributed by ICMA-RC Services LLC, a broker dealer affiliate of ICMA-RC, member FINRA/SIPC. For a paper copy of the current prospectus contact ICMA-RC Services LLC by phone at 1-800-669-7400 or by mail at 777 North Capitol Street NE, Washington, DC 20002-4240. You may also download a copy of the current prospectus.

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