Goldman Sachs direct indexing: TACS fees, minimum and what GSAM direct indexing really costs.
Goldman files two separate fee schedules for the same direct indexing strategy, and a third sits on a Merrill Lynch profile. The identical product costs 0.20%, 0.35% or 1.70% a year depending purely on who introduces you. Here are all three, from the filings.
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In short
Goldman Sachs direct indexing is sold under the name Tax Advantaged Core Strategies, or TACS, and is run by Goldman Sachs Asset Management, L.P. (SEC number 801-37591). There is no consumer signup: you reach it through an adviser, a wirehouse program, a distribution platform or Goldman Sachs Private Wealth Management. The price depends on which of those you use. GSAM's Form ADV Part 2A dated May 22, 2026 lists Index Oriented TACS at a flat 0.35% for third-party distributors. Merrill Lynch's Q2 2026 program profile prices the S&P 500 version at a 0.200% Style Manager Fee Rate with a $250,000 minimum. Goldman's own Private Wealth Management brochure, filed the same day, charges 1.700% on the first $10 million for the same Index Oriented TACS strategy. The portfolio itself holds 200 to 500 stocks against the S&P 500, runs tracking error below 1.4% if funded with cash and up to 6% if funded with appreciated stock, and turns over 25% to 200% a year.
Last updated August 2026
Goldman sachs direct indexing cost
One strategy, three prices, an 8.5x spread
This is the finding. Goldman does not have a direct indexing price. It has three, and the gap between the cheapest and the most expensive is not a rounding difference, it is a factor of eight and a half for a portfolio that is managed the same way in every case.
| How you access TACS | Annual manager fee | Source | What it does and does not include |
|---|---|---|---|
| Through a third-party distributor or platform | 0.35% | GSAM Form ADV Part 2A, Appendix A, p.175, May 22, 2026 | Manager fee only. The filing warns it "may not reflect the total fees paid by clients." |
| Through Merrill Lynch Investment Advisory Program | 0.200% | Merrill Lynch Investment Advisory Program Profile, Q2 2026 | Style Manager Fee Rate. The Merrill Program Fee is charged on top and is much larger. |
| Through Goldman Sachs Private Wealth Management | 1.700% | GSAM Form ADV Part 2A for Private Wealth Management, Appendix A, p.162, May 22, 2026 | All-in wealth management rate on the first $10 million. Includes a Goldman Wealth Advisor. |
Read that table carefully before drawing the obvious conclusion, because the three numbers are not measuring quite the same thing. The 0.35% and the 0.200% are manager-only fees: Goldman runs the money, and whoever introduced you charges their own fee on top. Merrill's Program Fee, for example, is charged separately and is far larger than the 0.200% that goes to Goldman. The 1.700% is different in kind. It is the all-in Private Wealth Management rate, and it pays for a Goldman Wealth Advisor who provides ongoing client service as well as for the portfolio management. The brochure says so: Wealth Advisors "will provide on-going client services with respect to assets of PWM clients managed by GSAMLP and will receive a portion of the fee charged by GSAMLP."
That caveat softens the comparison. It does not remove it. A 1.700% all-in fee on an index-tracking portfolio is still an extraordinary number in 2026, and Goldman's own filing tells you it is the ceiling rather than a typical negotiated outcome: "Absent special circumstances, the advisory fees associated with the first asset tiers ($0-10mm) set forth in the below schedules represent the maximum advisory fees that may currently be charged for new Wealth Management separately managed accounts." So 1.700% is the sticker price for a new private wealth client with under $10 million, and it is negotiable. The useful thing about seeing all three numbers together is knowing what the floor looks like when you negotiate.
Goldman sachs direct indexing fee
The two Form ADV schedules, exactly as filed
Distribution channel
Tax Advantaged Core Strategies (TACS)
GSAM Form ADV Part 2A, Appendix A, standard fee schedule, page 175.
| Strategy | Asset level | Fee |
|---|---|---|
| Index Oriented TACS | All asset levels | 0.35% |
No breakpoints at all. A $500,000 account and a $500 million account pay the same rate, which is unusual: every other GSAM equity strategy in the same appendix has five tiers and a minimum annual fee of $300,000 or $500,000. TACS has neither. The asterisk on the line explains why. The schedule is "intended for third-party distributors and /or financial institutions offering the Goldman Sachs Tax Advantaged Core Strategies (TACS) to clients through their distribution platform, and may not reflect the total fees paid by clients."
Private wealth channel
Index Oriented, Tax Advantaged Core Strategies
GSAM Form ADV Part 2A for Private Wealth Management, Appendix A, page 162.
| Account size | Annual fee |
|---|---|
| $0 to $10 million | 1.700% |
| $10 to $25 million | 1.100% |
| $25 to $50 million | 1.000% |
| $50 to $100 million | 0.900% |
| $100 to $250 million | 0.850% |
| $250 to $500 million | 0.800% |
| More than $500 million | 0.750% |
For context inside the same table, Goldman's Private Wealth fixed income SMA starts at 0.750% and its Dynamic Equity SMA starts at 2.290%. So index-oriented direct indexing is priced closer to active equity than to passive exposure. You need roughly $500 million with Goldman Private Wealth before the rate on this strategy falls to 0.750%, which is still more than double what the same strategy costs through a distributor.
Goldman sachs direct indexing minimum
$250,000 on the platform, nothing filed at the firm
The minimum is the question people search for most after the fee, and the honest answer is that Goldman does not publish one for TACS. Its brochure says GSAM "does not generally impose a minimum dollar value of assets in order to open or maintain an account", and that it instead considers "the minimum annual fee an account is expected to generate when determining whether to open or maintain an account". That is a soft gate, not a hard one, and it means the real threshold moves with the strategy and the relationship.
Two hard numbers do appear. GSAM states that "in the case of consulting or Wrap Programs sponsored by certain broker-dealers, GSAM generally requires clients to have minimum assets under management of $100,000". And Merrill Lynch lists a Managed Strategy Minimum Investment of $250,000 for Goldman Sachs Tax Advantaged Core Strategy S&P 500 on its Q2 2026 program profile. The $250,000 figure is the one to plan around, because it is attached to the specific strategy on a specific platform rather than to the firm in general. It also happens to match the strategy minimums at Parametric, Aperio and Vanguard, so a quarter of a million dollars is simply what adviser-channel direct indexing costs to enter.
One more line worth knowing before you rely on any of these numbers: "The actual fees, minimum fees and minimum account sizes for GSAM may be negotiated, and a client could pay more or less than the fees set forth in this Brochure, or more or less than similar clients or clients invested in similar strategies." Everything above is a starting point.
Goldman sachs tacs direct indexing
What a Goldman TACS S&P 500 account actually holds
Fee schedules tell you the price. This table, from Merrill Lynch's Q2 2026 program profile, tells you the product.
Style Manager Fee Rate
0.200%
Managed Strategy Minimum Investment
$250,000
Style index
S&P 500 Total Return
Average number of holdings
200 to 500
Annual turnover
25% to 200%
Tracking error, low active risk
below 1.4%
Tracking error, high active risk
up to 6%
Strategy inception on the program
February 2021
Benchmark adherence
High
The tracking error band is the part to negotiate
Most provider pages quote one tracking error number. Merrill quotes a range with a fourfold spread, and explains exactly what puts you in each half of it. Fund with cash and accept no restrictions and "the Style Manager will seek to manage the portfolio with low tracking error budget", with "an upper limit of 1.4% tracking error constraint". Fund with appreciated securities instead and Goldman "seeks to offer immediate transition in the first rebalance with tracking error up to 6%", because it is holding your low-basis positions rather than selling them into a tax bill.
Six percent tracking error is not a tracking difference, it is a different portfolio. On a year when the S&P 500 returns 10%, a portfolio with 6% forecast tracking error has roughly a two thirds chance of landing somewhere between 4% and 16%. That is the real trade being made when you transfer concentrated stock into a tax-managed account, and it is worth deciding deliberately rather than discovering it in the first quarterly statement. Merrill does note that Goldman "may eventually migrate High TE accounts to low tracking error (Low TE) throughout the course of the ongoing management".
Customization is narrower than the category average
Merrill lists the customization options as "exclusion of a security, sector and negative Environmental, Social and Governance (ESG) screens". That is exclusion only. There is no published ability to add a stock that is not in the index, or to overweight one that is, which is something Frec allows on up to 25 names and which anyone building a thesis-driven basket usually wants. Goldman's product is a cleaner, more institutional thing: track the benchmark, harvest the losses, screen out what you cannot own. If your goal is a portfolio that deliberately differs from the index, this is the wrong tool at any of the three prices.
One operational detail that catches people transferring in: "ETFs funded in-kind into the account will be sold unless the ETF is on an approved list (which is subject to change without notice)". If you are moving an existing ETF portfolio into TACS, expect most of it to be liquidated, which means realizing gains in the year you start. Ask for the transition analysis report first. Merrill notes Goldman "may run transition analysis report prior to enrollment that shows a detailed analysis of current holdings and how they would be transitioned in the strategy", and there is no reason not to insist on one.
Goldman sachs long short direct indexing
Three TACS strategies, and two of them use leverage
01
Index Oriented TACS
The plain version, and the one the fee schedules above are priced for. It samples an index, typically 200 to 500 names against the S&P 500, and harvests losses inside that basket while tracking the benchmark. This is what most people mean by Goldman Sachs direct indexing.
02
TACS with Index Call Writing
"A tax-advantaged equity buy-write strategy that aims to provide broad diversified exposure to US large cap equities with systematic index call writing, while also generating tax deferral benefits through tax loss harvesting." It requires a margin account, and the filing warns it "may create a straddle" if the option underlier resembles equity you hold elsewhere.
03
TACS Active Extension
The long/short version, which "utilizes both short sales and margin loans in an effort to deliver outperformance relative to the market while seeking to provide additional tax management opportunities relative to other tax aware strategies". It carries short sale risk, leverage risk, and the tax risk that "the IRS could challenge the tax benefits" of the structure.
The reason the long/short variants exist is loss decay. A long-only direct indexing account harvests aggressively in year one, less in year two, and eventually runs out of positions trading below cost. Adding shorts creates fresh loss-generating positions in a rising market, which is why every serious manager now sells one. Aperio charges an extra 0.20% to 0.40% for it, Frec's Long Short product runs 0.50% to 1.30% plus financing, and Goldman does not publish a separate TACS Active Extension rate at all. If a Goldman adviser proposes it, ask what the total cost is including margin, because the filing does not tell you.
What the risk disclosure says
Goldman manages the account standalone, and says so
"Unless otherwise agreed to in writing by GSAM, GSAM manages TACS Accounts on a standalone basis and does not consider any other assets that a client owns (including in other accounts managed by GSAM or its affiliates). Transactions in these outside accounts can trigger adverse tax consequences under U.S. Internal Revenue Service wash sale, straddle, or constructive sale rules."
GSAM Form ADV Part 2A, May 22, 2026, page 87
This is the single most important paragraph in the filing for anyone comparing providers, and it is the same gap Schwab discloses about its own program. A direct indexing account holds hundreds of individual stocks. If you also hold an S&P 500 fund in a 401(k), or your spouse holds one in a joint account, or you run a second SMA, then Goldman selling Apple at a loss while another account of yours buys Apple or an S&P 500 fund inside the 61 day window can disallow the loss. Goldman states plainly that "GSAM is not responsible for identifying wash sales across a client's portfolio."
The worst version is an IRA. Under IRS Revenue Ruling 2008-5, if the replacement shares are bought inside an IRA, the loss is disallowed and the IRA's basis is not stepped up, so the deduction is not deferred, it is gone permanently. Automatic contributions into a target date fund every payday are exactly the pattern that triggers this quietly, month after month, and nothing on your statement will flag it. Goldman also reserves the right to create wash sales deliberately: "in certain instances, GSAM may intentionally engage in wash sales when it believes that the trades are beneficial to do so."
And then there is the honesty at the top of the risk section, which is worth more than any marketing page. Goldman writes that harvesting reduces the average cost basis of the portfolio, which "creates a growing contingent future tax liability on unrealized gains", and that "if the account is eventually liquidated, the client will generally face immediate taxes on these realized gains". It goes further: "if the strategy fails to meet these tax-aware objectives, the after-tax result could be worse than if the client had not enrolled in the strategy at all". Direct indexing defers tax. It does not usually erase it.
Gsam direct indexing scale
Assets under management, as filed
| Registrant | Total AUM | Discretionary | Non-discretionary |
|---|---|---|---|
| GSAMLP (the US registrant) | $2,648,902,942,827 | $2,569,736,204,810 | $79,166,738,016 |
| GSAMI (International) | $621,020,040,973 | $620,971,050,525 | $48,990,448 |
| GSAMC (Japan) | $71,833,030,718 | $71,833,030,718 | $0 |
| GSAMHK (Hong Kong) | $21,189,475,396 | $21,189,475,396 | $0 |
| GSAMS (Singapore) | $13,777,866,083 | $13,777,866,083 | $0 |
Figures are as of December 31, 2025, from the assets under management table in the brochure. Treat these as the whole asset management firm rather than the direct indexing book: unlike Aperio or Vanguard Personalized Indexing, which are standalone registrants whose entire AUM is tax-managed indexing, GSAM files one number covering everything from money market funds to private credit. Goldman does not break out TACS assets anywhere in the filing, and any single figure you see quoted for "Goldman direct indexing AUM" did not come from the Form ADV. We are not going to invent one.
Goldman sachs direct indexing sma vs the rest
Where Goldman sits against every other provider
Four adviser-channel managers now cluster between 0.20% and 0.40%, and the retail platforms undercut all of them. Every figure below is verified from a provider filing or pricing page, with the date recorded in our notes.
| Provider | Minimum | Manager fee | Benchmarks | How you buy it |
|---|---|---|---|---|
| Goldman Sachs TACS | $250,000 via Merrill, none filed firm-wide | 0.20% via Merrill, 0.35% via distributors, 1.70% via GS Private Wealth | S&P 500 and other core indexes | Adviser or private wealth only |
| Aperio (BlackRock) | None filed, $250,000 via Morgan Stanley Select UMA | 0.35% US domestic, 0.40% foreign | Any benchmark, 50 to 1,000 holdings | Adviser only |
| Parametric Custom Core (Domestic Equity) | $250,000 direct, $25,000 via Select UMA | 35 bps manager fee | Any standard or custom benchmark | Adviser only |
| Vanguard Personalized Indexing | $250,000 via an adviser, $10,000,000 direct | 0.20% adviser tier 1, 0.27% direct tier 1 | Custom, adviser configured | Adviser only |
| Schwab Personalized Indexing | $100,000 | 0.40%, 0.35% above $2M | 6 strategies, no S&P 500 option | Direct to retail |
| Fidelity Managed FidFolios | $5,000 to be invested | 0.40% index, 0.70% active | 8 strategies | Direct to retail |
| Wealthfront S&P 500 Direct | $5,000 | 0.09% | S&P 500 | Direct to retail |
| Frec Classic | $20,000 to $50,000 | 0.09% to 0.35% | 25 indices | Direct to retail |
| S&P 500 index ETF | 1 share | 0.03% to 0.10% | One fund | Any brokerage |
Two conclusions come out of that table, and the first one is uncomfortable for the whole adviser channel. At the manager level, Goldman via Merrill (0.20%), Vanguard (0.20%), Parametric (0.35%), Aperio (0.35%) and Goldman via distributors (0.35%) are not competing with each other on price at all. They are clustered in a 15 basis point band. So if you have an adviser, the manager fee is close to a constant and you should choose on construction instead: whether the manager will benchmark to a custom index, how many holdings it runs, whether it will let you add names rather than only exclude them, and how it handles a securities-funded transition. Goldman is strong on the last of those and weak on the third.
The second conclusion is the one the 1.700% row forces. An S&P 500 ETF costs 0.03% and needs one share. Goldman TACS through Private Wealth Management costs up to 1.700% before you have harvested a single loss, which is roughly 19 times what Wealthfront charges for S&P 500 direct indexing and about 56 times the cost of the ETF. The published research does not support that gap. Wealthfront's own whitepaper measures tax loss harvesting at 0.18% to 0.44% a year of account value, and Vanguard's 1% to 2% claim applies only to clients who regularly realize large capital gains. If you do not already have gains to offset, IRS Topic 409 caps your net capital loss deduction against ordinary income at $3,000 a year, and the arithmetic simply does not work at any price above about 40 basis points.
Goldman sachs direct indexing review
What people ask about Goldman Sachs direct indexing
How much does Goldman Sachs direct indexing cost?
It depends entirely on which door you come through, and the spread is larger than for any other manager we have checked. Goldman Sachs Asset Management's own Form ADV Part 2A dated May 22, 2026 lists Index Oriented Tax Advantaged Core Strategies at a flat 0.35% for third-party distributors. Merrill Lynch's Q2 2026 program profile prices the same S&P 500 TACS strategy at a 0.200% Style Manager Fee Rate. Goldman's own Private Wealth Management brochure charges 1.700% on the first $10 million for the identical strategy. That is 0.20% to 1.70% for one product.
What is the minimum investment for Goldman Sachs direct indexing?
The concrete, verifiable number is $250,000, which is the Managed Strategy Minimum Investment that Merrill Lynch lists for Goldman Sachs Tax Advantaged Core Strategy S&P 500 in its Q2 2026 Investment Advisory Program profile. GSAM itself files no firm-wide minimum for TACS. Its brochure says it "does not generally impose a minimum dollar value of assets in order to open or maintain an account" and instead considers "the minimum annual fee an account is expected to generate". Separately, it requires $100,000 for broker-dealer wrap programs.
What is Goldman Sachs TACS?
TACS stands for Tax Advantaged Core Strategies, and it is the name of Goldman Sachs Asset Management's direct indexing business. The filing defines a "TACS Strategy" simply as "a tax-managed strategy" and describes it as "designed for U.S. taxable clients to realize capital losses (primarily short-term) and defer capital gains". It buys a sampled subset of an index directly, typically 200 to 500 stocks against the S&P 500, and harvests losses inside that basket rather than trading a single fund.
Can I open a Goldman Sachs direct indexing account myself?
No. There is no consumer signup for TACS the way there is at Fidelity, Schwab, Wealthfront or Frec. You reach it through an adviser, a wirehouse advisory program such as Merrill Lynch, a third-party distribution platform, or Goldman Sachs Private Wealth Management. If you want stock-level direct indexing you can open yourself, the retail options start at $5,000 with Fidelity Managed FidFolios and Wealthfront S&P 500 Direct.
How many stocks does a Goldman Sachs TACS portfolio hold?
Merrill Lynch reports an average of 200 to 500 holdings for the S&P 500 version, which means the strategy holds well under half the index. The profile is explicit that this is deliberate: it uses "a sampling approach and the manager does not do full replication", and notes that "a sampling approach also allows for tax loss harvesting". Annual turnover runs 25% to 200%, a very wide band, because harvesting activity depends on how much the market falls.
What tracking error should I expect from Goldman Sachs TACS?
Between under 1.4% and up to 6%, and which one you get is decided at funding. Merrill states the strategy "will be managed with tracking error below 1.4% for accounts with lower active risk and up to 6% for accounts with higher active risk". Cash-funded accounts with no restrictions get the low band. Accounts funded with appreciated stock get the high band, because Goldman is holding your existing positions to avoid triggering gains. A 6% tracking error is a genuinely different investment from an S&P 500 fund.
Does Goldman Sachs do tax loss harvesting across my other accounts?
No, and the filing is blunt about it. "Unless otherwise agreed to in writing by GSAM, GSAM manages TACS Accounts on a standalone basis and does not consider any other assets that a client owns (including in other accounts managed by GSAM or its affiliates)." It adds that "GSAM is not responsible for identifying wash sales across a client's portfolio". If you hold the same S&P 500 stocks in a 401(k), an ETF or a spouse's account, wash sales are yours to police.
Can direct indexing leave me worse off than not doing it?
Goldman says yes, in its own risk disclosure: "If the strategy fails to meet these tax-aware objectives, the after-tax result could be worse than if the client had not enrolled in the strategy at all." The filing also describes the loss-decay problem plainly. Harvesting "reduces" the average cost basis of the portfolio, which "creates a growing contingent future tax liability on unrealized gains", and "if the account is eventually liquidated, the client will generally face immediate taxes on these realized gains".
What are the three Goldman Sachs TACS strategies?
Index Oriented TACS is the plain direct indexing version that tracks a benchmark while harvesting losses. TACS with Index Call Writing is "a tax-advantaged equity buy-write strategy that aims to provide broad diversified exposure to US large cap equities with systematic index call writing", which requires a margin account and can create a tax straddle. TACS Active Extension is a long/short version that "utilizes both short sales and margin loans" to seek outperformance and extra harvesting capacity.
Is Goldman Sachs direct indexing worth 1.70%?
That is very hard to justify on tax alpha alone. Wealthfront's own published whitepaper puts the value of tax loss harvesting at 0.18% to 0.44% a year of account value. Vanguard claims up to 1% to 2% but only for clients who regularly realize large capital gains. At 1.70% you are paying more than the high end of the optimistic estimate before the strategy has done anything, and roughly 19 times what Wealthfront charges for S&P 500 direct indexing. The Private Wealth rate buys a Goldman relationship, not better harvesting.
How much money does Goldman Sachs Asset Management manage?
GSAMLP, the US registrant that files the TACS fee schedules, reported $2,648,902,942,827 in total assets under management as of December 31, 2025, of which $2,569,736,204,810 was discretionary. Adding the international, Japanese, Hong Kong and Singapore registrants brings the group past $3.3 trillion. Note that this is the whole asset management firm, not the direct indexing book: GSAM does not break out TACS assets in its Form ADV.
Is Goldman Sachs direct indexing suitable for a retirement account?
No, and Merrill flags it directly on the profile: "This Strategy may not be appropriate for retirement accounts or clients in low tax brackets." The entire point of tax loss harvesting is realizing losses that offset taxable gains. Inside an IRA or 401(k) there is nothing to offset, so you pay an active management fee for a benefit that cannot exist. Under IRS Revenue Ruling 2008-5, buying the replacement security in an IRA can even forfeit the loss permanently.
Sources
Distribution-channel fee schedule, account requirements and minimums, assets under management, TACS strategy definitions and the tax risk disclosures: Goldman Sachs Asset Management, L.P., Form ADV Part 2A brochure dated May 22, 2026, Items 4, 5, 7 and 8 and Appendix A, brochure version 1046043. Private Wealth Management separately managed account fee schedule: the same firm's Form ADV Part 2A brochure for Private Wealth Management dated May 22, 2026, Appendix A, brochure version 1046044. Both retrieved from the SEC's Investment Adviser Public Disclosure system for CRD number 107738, SEC file number 801-37591. Style Manager Fee Rate, strategy minimum, holdings range, turnover, tracking error bands, customization options, funding and transition treatment and the retirement account warning: Merrill Lynch Investment Advisory Program Profile, Goldman Sachs Tax Advantaged Core Strategy (TACS) S&P 500, Q2 2026, Bank of America product number 28S02441. Comparison figures for other providers re-verified from each provider's own pricing page or filing, dated in our published notes. Tax figures: IRS Topic 409, IRC 1091, IRS Revenue Ruling 2008-5, and the Wealthfront tax loss harvesting whitepaper. Indexes is not affiliated with, endorsed by or sponsored by The Goldman Sachs Group, Inc., Goldman Sachs Asset Management, L.P., Merrill Lynch or Bank of America. We are index construction and backtesting software: we do not manage money, place trades, custody assets or provide tax advice.
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