Indexes
Concentrated stock

Exchange funds: what is an exchange fund, what Eaton Vance and Cache charge, and the 20% nobody mentions.

Swapping a concentrated position into an exchange fund defers the whole capital gain. It also buys you a seven-year lockup and a mandatory illiquid sleeve. Here is the real pricing, the tax mechanics, and when direct indexing is the better route.

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Vendors' own published figures Checked August 2026 We do not run an exchange fund
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In short

An exchange fund is a partnership you contribute appreciated stock into, receiving a share of a pooled, diversified portfolio without triggering capital gains tax. The deferral comes from IRC Section 721. In return you accept a seven-year lockup, an annual fee that runs from about 0.40% to 2.00% depending on the provider, and a legal requirement that at least 20% of the fund sits in illiquid assets, usually private real estate. Traditional funds from Eaton Vance, now Morgan Stanley, and Goldman Sachs are aimed at qualified purchasers with $5 million in investments; newer providers such as Cache have cut the minimum to $100,000. The tax is deferred rather than forgiven, because your original cost basis carries over to the fund shares.

Last updated August 2026

// THE MECHANICS

What is an exchange fund

How an exchange fund actually works

Start with the problem it solves. You hold a position that has grown into most of your net worth, usually employer stock from a company that did well. Selling it means realizing a gain that can be taxed at up to 23.8% federal once you include the 3.8% net investment income tax, plus state. Not selling it means your financial life depends on one company's earnings calls. Both options are bad, which is why a structure that avoids choosing has existed since the 1970s. One caveat before you get this far: if any of that employer stock is still inside a 401(k), check the net unrealized appreciation treatment before the shares move anywhere, because the election is only available on the way out of the plan and it is gone once the balance is rolled to an IRA.

Step 1: you contribute, you do not sell

On one of the fund's scheduled exchange dates you transfer your shares into the partnership. Cache says it accepts contributions "typically twice per month," so this is a calendar, not a button. Because it is a contribution of property to a partnership under Section 721 rather than a sale, there is no realization event and no tax bill. Cache puts the benefit plainly: "Your full pre-tax value stays invested and compounding."

Step 2: you own a slice of everybody's stock

Your shares join a pool built from other investors' concentrated positions. You now own a proportional interest in that whole pool rather than a single ticker, which is the diversification you came for. What sits in the pool is whatever the other contributors happened to own, a detail that matters more than it sounds and that we come back to below.

Step 3: seven years pass

This is the price. The fund needs you to hold for seven years before you can redeem into a diversified basket of securities on the intended tax terms. Taking money out earlier is possible but structured to discourage you, and can put the original deferral at risk. Seven years is a long time to be unable to reach a large part of your net worth.

Step 4: you redeem, still deferred

After seven years you can take a pro rata share of the pooled securities, and again no gain is recognized. But your original cost basis comes with you. Contribute stock with a $10,000 basis and you eventually hold a diversified basket with a $10,000 basis. Nothing was forgiven. The gain was moved, spread across many names, and postponed.

That last point is the one to hold on to, because the whole case for an exchange fund rests on it. Deferral is genuinely valuable: the money you did not send to the IRS keeps compounding for seven years or longer, and if the shares are eventually held until death they may receive a step-up in basis that erases the gain entirely. Deferral is not the same as elimination, though, and any pitch that blurs the two is selling rather than explaining.

// THE 20%

Why exchange funds hold real estate

An S&P 500 exchange fund is not 100% S&P 500

This is the single most overlooked fact in the category, and it is not a secret. It is written into the structure by the tax code. Frec states it flatly in a footnote on its own comparison page:

"All exchange funds are required to maintain 20% in illiquid assets that tend to have additional management fees along with other costs."

frec.com, Diversify comparison footnote, read August 2026

The reason is a definition. Section 721 withholds the tax deferral if the partnership qualifies as an investment company, and a partnership qualifies as one when more than 80% of its assets are securities. So the fund must keep at least a fifth of its gross assets in something that is not a security. Publicly traded REITs will not do, because those are securities. What works is private real estate, and funds generally borrow to acquire it rather than selling the contributed stock they exist to hold.

Now put that next to the marketing. Funds in this category are sold as tracking the S&P 500 or the Nasdaq-100, with correlation figures quoted to two decimal places, and those claims can be perfectly accurate while the 20% sleeve still sits underneath them. A buyer who reads "S&P 500 exchange fund" and pictures owning the S&P 500 has mispriced what they are getting: at most about 80% of the fund is tracking equities, and the remaining fifth is a levered private real estate position they did not choose, carrying management fees the headline percentage does not include. We work through what that does to a specific fund's tracking on the Cache exchange fund page.

Whether that sleeve helps or hurts is a live question rather than a rhetorical one. Michael Kitces has made the arithmetic concrete: private real estate funds yield roughly 4% a year, so if the exchange fund pays more than 4% to borrow the money it used to buy that real estate, the sleeve generates a negative net income yield. In a higher-rate environment that is not a hypothetical. Ask any provider what the 20% currently holds, what it is levered at, and what it costs, because none of that is in the headline fee.

// TWO GENERATIONS

How much do exchange funds cost

Why nobody can quote you one price

Ask what an exchange fund costs and you will get a range so wide it is useless, somewhere between 0.40% and 2.00% a year. The range is wide because the category is really two different products sold to two different people, and most writing on the subject describes only the older one.

The traditional funds

Eaton Vance, now inside Morgan Stanley after the 2021 acquisition, and Goldman Sachs. These are private placements distributed through advisors and private banks, aimed at qualified purchasers. Minimums are widely reported at $500,000 to $1,000,000, and neither firm publishes a fee schedule or a minimum on a public page. There is no number to check, which is why anyone quoting you an exact Eaton Vance fee should be asked where it came from.

The newer funds

A recent generation, of which Cache is the most visible, sells to accredited investors instead, starts at $100,000 and publishes its pricing openly. That transparency is genuinely new in this market. For the tier-by-tier arithmetic, including how the rate falls as cumulative contributions rise and what happens to the fee after year seven, see our Cache exchange fund breakdown.

The gap that actually gates access is not the minimum investment, it is the eligibility standard, and it is the least discussed number in this category. A qualified purchaser is defined as holding $5,000,000 in investments. An accredited investor needs $1,000,000 in net worth excluding the primary residence, or $200,000 in income, $300,000 jointly. Moving from the first standard to the second expands the eligible population enormously, and that single change is what turned exchange funds from a private banking product into something you can read the price of on a website.

Two practical consequences. First, if you are researching this from a comparison article, check whether the fee range quoted describes the traditional funds or the newer ones, because a figure written for the wirehouse generation can overstate what you would actually pay by a wide margin. Second, whatever headline rate you are quoted, ask specifically whether the management costs of the mandatory 20% illiquid sleeve sit inside that number or on top of it. Those costs are real, they are rarely in the headline, and they are the part of exchange fund pricing that almost nobody asks about.

// EVERY ROUTE OUT

Exchange fund alternatives

Six ways out of a concentrated position, side by side

An exchange fund is one answer to the concentrated stock problem, not the only one. These are the routes a US investor with a large appreciated position is actually choosing between.

Route Minimum Who can use it Annual cost Lockup What you end up owning
Cache exchange fund $100,000 Accredited investor 0.40% to 0.95% Seven years Fund shares benchmarked to the S&P 500 or Nasdaq-100
Eaton Vance (Morgan Stanley) exchange fund Reported at $500,000 to $1,000,000, not published Qualified purchaser, $5M in investments Not published publicly Seven years A pro rata slice of the pooled portfolio
Goldman Sachs exchange fund Reported at $500,000 to $1,000,000, not published Qualified purchaser, $5M in investments Not published publicly Seven years A pro rata slice of the pooled portfolio
Frec Diversify (long/short transition) $100,000 No accreditation requirement stated 0.60% to 1.10% plus financing cost None A direct index you own outright
Plain direct indexing (Wealthfront, Frec Classic) $5,000 to $20,000 None 0.09% to 0.35% None Individual stocks you own outright
Sell the position and pay the tax None None Nothing ongoing None Cash, minus up to 23.8% federal on the gain

Read the eligibility column before the fee column. The traditional funds are private placements sold to qualified purchasers, which the SEC defines as holding $5,000,000 in investments. That threshold, not the minimum investment, is what has historically kept exchange funds a product for the already wealthy. The newer providers run on the accredited investor standard instead, which needs $1,000,000 in net worth excluding your primary residence, or $200,000 in income ($300,000 jointly). That single change in eligibility standard is what opened the category up, and it is why the pricing suddenly became public.

For a full breakdown of the direct indexing routes in the last two rows, including who has the lowest fee at each account size, see our comparison of direct indexing platforms, and the head-to-head on Frec Diversify against the Cache exchange fund.

// THE IRONY

What is actually inside the fund

You joined to fix concentration. The fund may still be a tech bet.

An exchange fund does not go out and buy a diversified portfolio. It receives one, from its investors, and it holds whatever they contributed. So the question of what is inside is really a question about who else showed up. The answer, historically, is people with enormous unrealized gains in technology stocks, because that is where enormous unrealized gains have come from.

Kitces reports that exchange funds have tended to resemble high-growth technology funds, running around 60% technology against roughly 33% for the S&P 500. If that describes the fund you are joining, and the concentrated position you are trying to escape is your own employer's technology stock, you have reduced single-name risk substantially while barely touching sector risk. That is a real improvement. It is not the improvement most buyers think they are getting.

The newer funds benchmarked explicitly to the S&P 500 or the Nasdaq-100 are a partial answer to this, since they manage toward an index target rather than accepting whatever arrives. Cache's stated 0.99 correlation figure is a claim about exactly this. But it is a claim worth asking about specifically, because the underlying mechanism has not changed: the fund still has to accept contributed stock, and it still has to carry the 20% sleeve. Ask for the current sector breakdown before you commit for seven years, and compare it against what you already own. Modeling the sector weights you actually want, then measuring the gap against a real portfolio, is the kind of question worth answering before the money is locked up rather than after.

// BOTH SIDES

Exchange funds pros and cons

What you get and what you give up

The case for

  • Your whole position keeps working. No tax is paid on entry, so 100% of the pre-tax value stays invested instead of up to 23.8% federal leaving immediately.
  • Diversification happens on day one. Not over five years of careful selling, but at the next exchange date.
  • The deferral can become permanent. Held until death, the position may receive a step-up in basis, which is the reason this structure has been a staple of estate planning for decades.
  • No decisions to make for seven years. For an investor who has been paralyzed about the position for a decade, that is a feature rather than a cost.

The case against

  • Seven years is genuinely illiquid. Plans change, and this money will not be reachable on reasonable terms if yours do.
  • The 20% sleeve is not optional. A fifth of your money goes into levered private real estate you did not select, with its own fees.
  • Fees compound against the benefit. Kitces makes the sharp version: underperformance of about 2% a year can significantly reduce or completely wipe out the value of the tax saving.
  • You still owe the tax. The basis carries over. Unless the step-up eventually applies, this is a timing benefit, not a forgiveness.
  • You give up control entirely. No say in the holdings, the weights, or the sector mix.
// THE ASYMMETRY

What is the 7 year rule for exchange funds

The early exit option is structured against you

Most write-ups describe the seven-year rule as a lockup and move on. The detail worth knowing is what happens if you try to leave anyway, because the terms are not neutral. A distribution taken inside the seven-year period is limited to the lesser of the current market value of what you contributed or your pro rata share of the fund.

Work through both directions. If the fund has done well and your pro rata share is now worth more than your original contribution, the cap hands you the smaller number and the fund keeps the difference. If the fund has done badly and your share is worth less than you put in, the cap is the share, and you take the loss. You hold the downside in both scenarios. That is a deliberately unattractive door, and it is unattractive by design, because the structure only works if capital stays put.

So the seven years should be treated as a genuine constraint rather than an inconvenience with an escape hatch. Before committing, the honest test is whether you could fund a house, a divorce, a medical event, a business, or a tax bill from other assets for the whole period. If the answer is no, the lockup is the deciding factor and the fee comparison is beside the point. This is also where the direct indexing route earns its keep, because it trades a slower exit from the position for the ability to change your mind at any point.

// THE REAL CHOICE

Exchange fund vs direct indexing

Defer the whole gain, or grind it down while staying liquid

These two answers to the same problem work in opposite directions, and most buyers evaluating an exchange fund should look at the other one before signing.

The exchange fund defers everything at once and charges you illiquidity for it. The direct indexing route defers nothing upfront. Instead you move the concentrated position into an account that builds an index around it and systematically harvests losses elsewhere in the portfolio, using those realized losses to offset the gains as the position is sold down piece by piece. It is slower and it does not avoid the tax so much as pay it efficiently. What it preserves is optionality: no lockup, real shares you own outright, and the ability to stop at any point.

Frec publishes the timeline comparison on its own Diversify page and it is the most useful single number in this debate: a transition at roughly a 50% cost basis takes one to five years, against seven for an exchange fund, against immediate for simply selling and paying. The cheaper your basis, the longer the grind takes and the more the exchange fund's immediate deferral is worth. If your basis is high, the exchange fund is mostly buying you a lockup you did not need.

One more consideration that cuts against the exchange fund and rarely appears in the sales conversation. Loss harvesting only converts into cash value when you actually have realized gains to offset, and once a direct indexed portfolio has been held for years its cost bases drift upward and the harvesting opportunities thin out. We walk through both effects in direct indexing tax loss harvesting, including why the 1% to 2% tax alpha providers advertise comes to 0.18% to 0.44% in Wealthfront's own published research. Neither route is free money. Both are worth pricing honestly.

// WHERE WE FIT

Being straight about this

We do not run an exchange fund, and we are not going to pretend otherwise

What we do not do

We do not operate an exchange fund, custody assets, place trades, harvest losses or track cost basis, and we are not a registered investment adviser or a tax advisor. Nothing here is tax or investment advice. A concentrated position large enough to justify an exchange fund is large enough to justify a CPA who knows your full picture.

What we do instead

We are the modeling layer that runs before you commit. Define the diversified portfolio you actually want, weight it the way you want, backtest that exact construction over real market history, and track it as a named index against the S&P 500. No minimum, from $12 a month.

That sequence is specifically useful here because a seven-year lockup is not a decision you get to revise. Before you hand a position over, it is worth knowing what you want to be holding on the other side: how much technology exposure you are comfortable with, whether an equal-weighted construction would have behaved differently from a cap-weighted one through the drawdowns you care about, and what the fund's sector mix would do to a portfolio you already own. Those are answerable questions, they cost nothing to answer, and no provider's pricing page addresses them. If you want the wider context first, start with what direct indexing is or run the numbers on comparing your portfolio to the S&P 500.

// FAQ

Questions

Exchange funds, answered

What is an exchange fund?

An exchange fund is a partnership that lets several investors each contribute a concentrated stock position into one pooled portfolio, and receive a share of the pool in return. Because the contribution is treated as a partnership contribution under IRC Section 721 rather than a sale, no capital gains tax is triggered on the way in. You end up diversified without having sold anything. The trade is a seven-year commitment and a fee.

How do exchange funds work?

You contribute appreciated shares on one of the fund's scheduled exchange dates. The fund pools your stock with everybody else's and, because it must not be classified as an investment company under Section 721, tops the portfolio up with at least 20% in qualifying illiquid assets, in practice private real estate bought partly with borrowed money. You hold fund shares for seven years. After that you can redeem for a pro rata basket of securities, still without triggering the original gain.

What are the pros and cons of exchange funds?

The pro is real: you diversify a concentrated position with your full pre-tax value intact, so the money that would have gone to the IRS keeps compounding for you. The cons are a seven-year lockup, an annual fee between roughly 0.40% and 2.00% depending on the provider, a mandatory 20% illiquid sleeve you did not choose, an underlying portfolio that may be far more technology-heavy than the index it is benchmarked to, and the fact that your original cost basis follows you, so the tax is deferred rather than forgiven.

What is the minimum investment for an exchange fund?

It depends entirely on the provider generation. The traditional wirehouse funds from Eaton Vance, now part of Morgan Stanley, and Goldman Sachs are widely reported at $500,000 to $1,000,000, though neither firm publishes the figure on a public page. Newer entrants have pushed it down: Cache advertises "Start with $100K, not $1M." Frec Diversify, which is not an exchange fund but competes for the same buyer, also starts at $100,000.

How much do exchange funds cost?

There is no single answer, and the two vendors who publish figures disagree. Cache lists 0.40% to 0.95% on its own product page. Frec's comparison footnote, marked as data from March 2026, says most exchange funds charge approximately 0.70% to 2.00% with lower fees at higher contribution levels. Both are quoted from the firms themselves. On top of the headline fee, the mandatory 20% illiquid sleeve carries its own management costs that the headline number does not include.

What is the 7 year rule for exchange funds?

Seven years is the holding period the fund needs you to serve before you can redeem into a diversified basket of securities without the exchange being recharacterized. It is not a soft guideline you can negotiate. If you take a distribution inside the seven years, the amount is limited to the lesser of the current market value of what you put in or your pro rata share of the fund, which means the early-exit option is structured against you.

Why do exchange funds hold real estate?

Because of a definition in the tax code, not because anybody thinks real estate improves the portfolio. Section 721 denies tax deferral if the partnership counts as an investment company, and a partnership counts as one if more than 80% of its assets are securities. Holding at least 20% in qualifying illiquid assets keeps the fund under that line. Publicly traded REITs do not work for this, so it is private real estate, typically funded with borrowing.

What happens to my cost basis in an exchange fund?

It follows you. If you contributed stock with a $10,000 basis, your fund shares carry a $10,000 basis, and when you eventually redeem, the securities you receive carry it too. That is the whole mechanism: the tax is deferred, not erased. The only ways the gain genuinely disappears are the step-up in basis at death or donating the appreciated position to charity, neither of which requires an exchange fund.

Can I get out of an exchange fund early?

You can request a distribution, but the terms are deliberately unattractive. An in-period distribution is capped at the lesser of the current market value of your contribution or your pro rata share of the fund, so if the fund has appreciated you receive the smaller original figure, and if it has fallen you absorb the fall. Exiting early can also put the original tax deferral at risk. Treat the seven years as money you genuinely cannot reach.

Exchange fund vs ETF: what is the difference?

An ETF is something you buy with cash, which means selling your concentrated position first and paying tax on the gain. An exchange fund is something you buy with the stock itself, so no sale happens and no tax is triggered. An ETF is liquid daily, cheap, and holds only securities. An exchange fund locks you in for seven years, costs several times more, and must hold 20% in illiquid assets. You are paying the difference for the deferral.

Do Fidelity or Schwab offer exchange funds?

These are two of the most common searches on the topic, and the honest answer is that exchange funds are private placements distributed through advisors, wirehouses and private banks rather than sitting in a retail brokerage product menu next to the mutual funds. If you hold your concentrated position at a retail brokerage, the practical route is to ask an advisor which funds you are eligible for, not to look for a buy button. Verify current availability with the firm directly rather than trusting any article, including this one.

What is the Eaton Vance exchange fund?

Eaton Vance ran one of the longest-established exchange fund programs in the US and was acquired by Morgan Stanley in 2021, so the offering now sits inside Morgan Stanley Investment Management. It is a traditional, advisor-distributed fund aimed at qualified purchasers, with minimums widely reported at $500,000 to $1,000,000. Neither Eaton Vance nor Morgan Stanley publishes the fee schedule or the minimum on a public page, so anyone quoting an exact Eaton Vance fee to you should be asked for the source.

Is an exchange fund a good idea for a concentrated stock position?

It is a good fit for a specific shape of problem: a large, deeply appreciated position, a genuine seven-year horizon, no need for the money in between, and estate plans that might eventually deliver a step-up in basis. It is a poor fit if you want the money sooner, if you want control over what you own, or if the position is small enough that the fee and the illiquid sleeve eat the tax saving. Kitces makes the sharp version of that point: underperformance of about 2% a year can wipe out the entire benefit.

Is an exchange fund better than direct indexing?

They solve different problems and the honest answer depends on your basis. An exchange fund defers 100% of the gain immediately and locks you up for seven years. Direct indexing defers nothing upfront; it grinds the position down over time using harvested losses, which is slower but leaves you liquid, in control, and holding real shares. Frec puts the timelines side by side on its own page: roughly one to five years for a transition at a 50% cost basis, against seven for an exchange fund. The lower your basis, the more the exchange fund's immediate deferral is worth.

Who are the main exchange fund providers?

Two groups. The traditional funds come from Eaton Vance, now part of Morgan Stanley, and Goldman Sachs, sold through advisors and private banks to qualified purchasers, with minimums reported at $500,000 to $1,000,000 and no published pricing. The newer group, of which Cache is the most visible, sells to accredited investors from $100,000 and publishes its fees. Availability changes, so confirm eligibility and current terms with the provider rather than trusting any list, including this one.

Know what you want to own before you lock it up for seven years

Build the weighted index you actually want, backtest that construction over real market history, and track it against the S&P 500. No minimum, no account to link, no trades placed. Educational and informational only, not tax or investment advice.