Felipe Cousiño, Partner
Francisca Donoso, Senior associate
Laura Tressler, Associate
On June 6, 2025, the securities, banking and insurance regulator (Comisión para el Mercado Financiero – “CMF”) published for comment the proposed annual update to the maximum total expense ratios (“Max TERs”) applicable to investments made by Chilean pension funds. These limits are jointly set with the Chilean Pension Regulator (Superintendencia de Pensiones – “SP”). The excess over such Max TER must be borne by the pension fund managers (“AFPs”).
As may be noted in the chart below, some Max TERs are raised, and others are lowered. For example, equity mutual funds mostly remain unchanged or slightly decrease, while fixed income mutual funds and ETF categories show modest increases in several segments. No distinction continues to be made between actively managed and passive ETFs.
Notably:
- Max TERs for liquidity funds (i.e. money market funds) saw a rise from 0.21% to 0.24%.
- Max TERs for emerging market equity ETFs increased from 0.72% to 0.75%.
- Max TERs for private equity and private debt both rose from 2.35% to 2.40%.
- Max TERs for private equity Funds of funds for both private equity and debt increased to 3.81%.
- Max TERs for gold ETFs slightly decreased from 0.93% to 0.91%.
The data sources and statistical methodologies used to determine these values were Morningstar for registered funds and Preqin for private equity and credit.
Additionally, Chilean feeder fund fee reporting must continue to comply with the ILPA standard, in line with sponsors receiving direct investments.
Updated Maximum TERs (2025–2026)
| Foreign and domestic mutual funds and domestic Closed-End Funds (transferable) | ||||
| Asset type | Geographical Zone | Business style | Old Maximum TER | New Max TER |
| Stocks (Equity) | Developed, Emerging and | Index | 0.30% | 0.30% |
| Developed and Global | Others | 0.99% | 0.99% | |
| Emerging | Others | 1.18% | 1.17% | |
| Bonds (Fixed income) | Developed | Index | 0.11% | 0.12% |
| High Yield | 0.80% | 0.80% | ||
| Others | 0.63% | 0.64% | ||
| Emerging | 0.95% | 0.96% | ||
| Global | 0.71% | 0.75% | ||
| Balanced | 0.97% | 0.97% | ||
| Liquidity | 0.21% | 0.24% | ||
| Exchange Traded Funds (ETFs) | ||||
| Asset type | Geographical Zone | Business style | Old Maximum TER | New Max TER |
| Stocks (Equity) | Developed and Global | 0.60% | 0.60% | |
| Emerging | 0,72% | 0.75% | ||
| Bonds | Developed and Global | Others | 0.39% | 0.42% |
| Emerging | 0.50% | 0.53% | ||
| Developed and Global | High Yield | 0.50% | 0.53% | |
| Alternative Assets | ||||
| Investment type | Old Maximum TER | New Maximum TER | ||
| Private Equity (includes co-investment) | 2.35% | 2,40% | ||
| Private Debt (includes co-investment) | 2.35% | 2.40% | ||
| Private Equity Funds of Funds | 3.75% | 3.81% | ||
| Private Debt Funds of Funds | 3.75% | 3,81% | ||
| Domestic Closed-End Real Estate and Infrastructure Funds | 2.00% | 2,01% | ||
| Gold ETFs | 0.93% | 0,91% | ||
If you need more information, please do not hesitate to contact our Capital Markets team.