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Understanding Collective Investment Trusts & Alternative Strategies

by Deborah Hogan

May 23, 2025 Collective Investment Trusts, Investment Companies

Collective investment trusts (CITs) aren’t new — but they’ve quietly positioned themselves for the next major evolution in the retirement investment landscape. According to reports from the SEC and ICI, as of December 31, 2024, CITs accounted for $7 trillion of the $12.4 trillion in defined contribution (DC) plan assets. For those unfamiliar with the product, this may come as a surprise. But for industry insiders, this growth has been long anticipated. A panel at our recent Cohen Client Conference tackled this topic head on. Below are some of the insights the group shared.

CITs Through the Years:

  • 1927: First collective investment fund organized under state law
  • 1962: Supervisory responsibility transferred from the Federal Reserve to the OCC
  • 1974: Employee Retirement Income Security Act (ERISA) enacted
  • 2006: Pension Protection Act (PPA) enables new default investment options in 401(k) plans
  • 2024: CITs surpass mutual funds as the most used target-date vehicle
  • 2025: SECURE 2.0 Act reintroduced, proposing the inclusion of CITs in 403(b) plans

CITs offer a compelling combination of low costs, regulatory oversight and investment flexibility. Their operating expenses are significantly lower than mutual funds, without the extreme fee compression experienced by exchange-traded funds (ETFs). This cost efficiency is largely due to streamlined regulatory requirements. CITs must produce annual audits and comply with GAAP financial reporting standards, but they are not subject to the SEC’s extensive public disclosure mandates. There are no requirements for public filings, quarterly holdings reports or registration statements — reducing legal and compliance expenses and enabling faster product launches, typically averaging three months when using experienced service providers.

Historically, some investors have criticized CITs for a lack of transparency. However, technology and market evolution have diminished the validity of that concern. Today’s CITs are structured with intentional flexibility — often providing daily valuation and liquidity much like their registered counterparts. For long-term retirement investors, the advantages of lower fees, flexible structures and liquidity options often outweigh the need for more frequent performance reporting.

Beyond their mainstream role in target-date funds, CITs are increasingly viewed as a platform for innovation. The industry is shifting from a reactive stance to proactive product development. With growing awareness and acceptance of CITs, asset managers are exploring how the structure can support more diverse and sophisticated investment strategies, such as private credit. Notably, CITs are not bound by the same regulatory constraints as mutual funds or ETFs. For example, CITs are not capped at 15% illiquid investments or restricted in their use of derivative leverage. Instead, they are supported by qualified investors and robust operational oversight.

For firms seeking to broaden their investment offerings and meet evolving client needs, CITs present a powerful and efficient solution. Partnering with an experienced trustee allows asset managers to focus on delivering performance, while the trustee manages operational compliance and cost control through established service provider networks.


CITs have steadily expanded their presence in the retirement market — yet significant growth potential remains. For many investors and asset managers, the best may be yet to come.

Contact Deborah Hogan or a member of your service team to discuss this topic further.

Thank you to our panelists for participating in this session with us: Camille Clemons, Market Leader, Alternative Investments, Cohen & Co; Scott Graham, Executive Vice President, Chief Investment Officer, GTC; Vincent Manning, Executive Vice President, Chief Development Officer, GTC; Mike Meckstroth, Partner, Cohen & Co.

In this blog Cohen & Co is not rendering legal, accounting, investment, tax or other professional advice. Rather, the information contained in this blog is for general informational purposes only. Any decisions or actions based on the general information contained in this blog should be made or taken only after a detailed review of the specific facts, circumstances and current law with your professional advisers.

About the Author

Deborah Hogan, CPA

Senior Manager, Cohen & Co Advisory, LLC
dhogan@cohenco.com
414.203.6325

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