When the old fund sits in a taxable account with large gains. Counterexample, illustrative with federal rates from IRS Topic 409: you hold $150,000 of SPY bought for $60,000. Selling realizes a $90,000 long-term gain; at the 15% rate that is $13,500 of federal tax. Moving the remaining $136,500 to VOO saves 0.0645% a year, about $88 ($136,500 × 0.0645%). Because both funds grow at the same market rate, the smaller balance catches up only through that fee gap: (150,000 ÷ 136,500)^(1/n) − 1 = 0.0645% gives n = ln(1.0989) ÷ ln(1.000645) ≈ 146 years, far longer than any retirement. Inside an IRA or 401(k) the same switch has no tax cost, so it can make sense there.
The bigger question is usually elsewhere. A saver who owns an S&P 500 fund, a Nasdaq-100 fund and a few large tech stocks holds one concentrated bet three times; see how concentrated the S&P 500 is and how much VOO, QQQ and VTI overlap. And a 60-year-old fully in stocks gains nothing from picking SPYM over SPY compared with deciding how much belongs in bonds (see how to choose ETFs for retirement).