The whole bill, not the headline

The expense ratio is not what your ETF costs.

Fee waivers with an expiry date, the fees of funds held inside, what the fund spends trading, the spread you pay to get in, and the capital gains it hands you in a year you sold nothing. All filed. None of it in the number on the fact sheet. Anything unsourced reads N/A.

Seed identifiers · every cost figure lands with the pipeline · not a recommendation

As at 2026-08-18

The problem

Comparing expense ratios is not comparing costs.

You are shopping on one line

Fact sheets quote an expense ratio, so that is what gets compared. It leaves out what the fund pays to trade, what it pays any fund it holds, and the tax bill it can hand you at year end.

Today’s price may have an expiry date

A headline ratio is often a net figure that exists because the adviser is waiving part of its fee. The waiver is contractual, the expiry is in a footnote, and nothing tells you when it lapses.

The receipt already exists

Every fund reports what it actually returned against its index, what it spent trading, and every dollar it distributed. It is filed with the SEC, and almost no screener reads it.

The cost stack

The expense ratio is one line of an 8-line bill.

Only 2 of these 8 layers are fully inside the number on the fact sheet. 4 are never in it, and two are in it only conditionally — one of them until a date printed in a footnote. All of them are filed somewhere.

Layer What it is Which filing states it In the ratio?
Management fee What the adviser charges to run the fund. The biggest line, and the one on the fact sheet. Prospectus fee table Yes
Other operating expenses Custody, administration, legal, transfer agency and the rest of running a registered fund. Prospectus fee table Yes
Fee waiver Many funds quote a net expense ratio that exists only because the adviser is waiving part of its fee — under a contract with an expiry date printed in the footnote. Prospectus fee table, footnote Partly
Acquired fund fees If the fund holds other funds, it pays their fees too. Disclosed as AFFE, and routinely left out of the ratio quoted in marketing. Prospectus fee table, as AFFE Partly
Trading costs What it costs the fund to trade its own portfolio. Commissions are in the annual report; turnover is the published proxy for how much trading there is. Annual report and SAI No
Bid-ask spread What you give up on the way in and again on the way out. Not the fund’s cost — yours — and invisible in every fee figure. Market data No
Capital gains distributions A fund that has to realise gains hands you a tax bill in a year you sold nothing. ETFs mostly avoid this. Mostly is not always. Distribution history, Form 1099 No
Foreign withholding tax On a fund holding non-US securities, tax is withheld at source before the fund ever receives the dividend. Treaty rates and the fund’s holdings No

One figure nets the lot after the fact: tracking difference — what the fund actually returned against what its index did. It is the closest thing to a receipt, and it is why we carry it beside the fees rather than instead of them.

Withholding drag

The tax you never get back, and never see.

A fund holding foreign stocks has tax deducted at source before it ever receives the dividend. Whether that money comes back to you turns on two facts no fee comparison shows: how much of the fund is foreign, and which account it sits in.

What the fund holds Taxable accountIRA / 401(k) / Roth
Holds only US securities No foreign dividends, so nothing is withheld at source. Nothing withheldNothing withheld
Majority foreign Over half the fund is foreign securities, so it can elect to pass the foreign tax through to you. CreditableLost
Partly foreign Foreign holdings under the statutory threshold. The fund cannot make the pass-through election at all. LostLost

Why a retirement account is the worst place for it

The foreign tax credit works by offsetting US tax you owe. Inside an IRA or a 401(k) there is no liability that year to offset, so the withheld tax is simply gone — not deferred, gone. The fund’s expense ratio is identical in both accounts; the actual cost of holding it is not.

The threshold nobody mentions

A fund can only pass the credit through to you if it is majority-foreign at year end. A global fund that sits under that line pays the foreign tax and absorbs it, and you cannot claim a cent of it — in any account. It is a statutory test, not a judgement call, and it is nowhere in the fee table.

How the rules operate, not tax advice · your own treatment depends on facts we do not know — see the disclaimer

Our solution

What we are building the CleanList around.

These are the rules we intend to hold funds to. The thresholds are not final and are not applied yet — we would rather say that than imply a screen we have not finished. A fund makes the list when the whole stack is known, not when one line of it is.

  • The gross and net expense ratios are both read from the prospectus fee table that states them.
  • Where a waiver creates the net figure, its contractual expiry date is recorded — a price with an end date is not the same price.
  • Acquired fund fees are counted where the fund holds other funds, from the fee table rather than inferred.
  • The fund’s legal structure is on record, because it decides what it may hold, what it may lend, and what tax form you receive.
  • The reported tracking difference reconciles against the cost stack, or the gap is flagged rather than smoothed over.

Features

Built on what is filed, not on an assumption.

All-in cost, not the headline

The net expense ratio plus the fees of any fund held inside — summed only when both are known, because a partial sum is worse than a blank.

Waivers, with their expiry

Where a cheap ratio exists only because the adviser is waiving part of its fee, we carry the gross figure and the date the waiver runs out.

Structure on every fund

Open-end fund, unit investment trust, grantor trust or commodity pool — which decides what it may hold, what it may lend, and what tax form arrives.

Spread as a cost

The median bid-ask spread, priced as what it is: money you pay on the way in and again on the way out.

Capital gains handed to you

What the fund distributed as gains, so a tax bill in a year you sold nothing is something you saw coming.

Sourced, or N/A

Every figure cites the filing it came from. Nothing is estimated, interpolated, or filled in with a number that looks right.

How it works

Four steps, no black box.

  1. Step 1

    Read the fee table, not the fact sheet

    The prospectus fee table carries the gross ratio, the net ratio, the waiver behind the gap and acquired fund fees. The fact sheet carries one of those.

  2. Step 2

    Find the expiry

    A waiver is a contract with an end date, printed in a footnote. We record the date, so a price that is about to change is not shown as a price that is not.

  3. Step 3

    Read the annual report

    What the fund actually spent trading, what it distributed as capital gains, and how it did against its index — the filed record, not a marketing summary.

  4. Step 4

    Reconcile against the receipt

    The stack has to explain the reported tracking difference. Where it does not, the fund is flagged — an unexplained gap is information, not noise to round away.

Pricing

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The whole tool, for every fund we cover.

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Included

  • The full CleanList with all-in cost, not just the headline ratio
  • Gross and net expense ratios, with the waiver and its expiry date
  • Acquired fund fees, where the fund holds other funds
  • Legal structure on every fund, and what it changes
  • Median bid-ask spread as a stated cost
  • Capital gains distribution history
  • Tracking difference against the index, from the fund’s own report
  • New funds as they clear verification

FAQ

Questions worth asking first.

Isn’t the expense ratio the total cost?

No, and it was never meant to be. The ratio covers the management fee and the fund’s operating expenses. It excludes what the fund spends trading its own portfolio, it usually excludes the fees of any fund held inside, it says nothing about the spread you pay to buy shares, and it cannot tell you about a capital gains distribution you will owe tax on. None of that is hidden — it is filed, just somewhere other than the fact sheet.

What is a fee waiver, and why do you show two ratios?

Many funds quote a net expense ratio that is lower than what the fund would otherwise charge, because the adviser has contractually agreed to waive or reimburse part of its fee. That agreement has an expiry date, printed in a footnote to the prospectus fee table. We carry the gross figure, the net figure and the expiry, because a price that ends on a known date is not the same as a price that does not.

Where does the data come from?

The filings: the prospectus and its fee table for the fee structure, the statement of additional information and the annual report for what the fund actually spent and distributed, and the fund’s portfolio reports for what it holds. Every figure is attributed to the filing it came from, and anything unsourced reads N/A rather than being filled in with a guess.

Why does it matter which account I hold it in?

Because the foreign tax credit works by offsetting US tax you owe, and inside an IRA or a 401(k) there is nothing to offset. Tax withheld on a fund’s foreign dividends is simply lost there — not deferred, lost — while the same fund in a taxable account can generally pass that credit through to you. There is a second catch: a fund has to be majority-foreign at year end to make that pass-through election at all, so a global fund holding a minority of foreign stock absorbs the tax in every account. The expense ratio is the same in all of these cases. The cost is not.

Why don’t I see some tickers?

Coverage is deliberately narrow. A fund reaches the CleanList only once its whole cost stack is known and reconciles — not when we have found its expense ratio. Those criteria are still being finalised, and the page that lists them says so. A fund you hold that is missing is usually waiting on that check rather than failing it.

Is this investment advice?

No. It is a research and comparison tool. It reports what funds file and derives figures from those inputs, and where it describes tax it is describing how a published set of rules works rather than what you should do about it. Nothing here is a recommendation, and none of it is tax advice — see the disclaimer.

Find out what you are actually paying.

Every layer of the bill, for every fund on the CleanList — and the one line that changes depending on which account you hold it in.