Boston Federal Reserve Bank President Eric Rosengren talked on "​Towards Greater Financial Stability in Short-​Term Credit Markets" in Sweden yesterday. He said, "I will highlight that the structure of the U.​S. money market mutual fund (​MMMF) industry -- and the practice of many financial institutions to fund long-​term dollar assets with short-​term dollar liabilities -- have both helped make the global financial system susceptible to liquidity shocks and (​relatedly) to changes in the perceived credit risk of market participants. I will first discuss the role that MMMFs play in providing short-​term funding, including serving as an important source of short-​term financing for European banks. I will highlight that the current structure makes MMMFs particularly susceptible to credit shocks that can turn into liquidity problems for the whole industry -- and will suggest some ways that the industry could be made more resilient. And I will then turn to the practice among some European banks of funding long-​term dollar assets with short-​term paper purchased by MMMFs. This too, has proved to be a structure that makes short-​term credit markets susceptible to liquidity shocks."

Bloomberg BusinessWeek writes "​Money Market Investors May Get Relief From Fed'​s Operation Twist". It says, "Investors in U.​S. money market funds may get some relief from record-​low returns when the Federal Reserve begins to sell short-​term debt as part of its latest stimulus effort that'​s been dubbed Operation Twist. The rate to borrow and lend Treasuries for one day in the repurchase agreement market may rise six to eight basis points, according to Barclays Plc. Overnight general collateral repo agreements for Treasuries averaged 0.​069 percent since June, while one-​month Treasury bill rates averaged 0.​0113 percent. The one-​month bill has traded below zero almost every day since mid-​August. The Fed'​s plan to begin selling $​400 billion of Treasuries due in three years and less next month to fund purchases of a similar amount of longer-​maturity debt comes as investors park cash in money funds. Investors have been seeking a refuge from Europe'​s debt crisis and slowing growth. Custody banks have also been hurt by persistent low interest rates, which reduce income from lending cash and securities and cut fees from the funds. Bank of New York Mellon Corp., the world'​s largest custody bank, said last month it will begin charging customers for '​extraordinarily high' cash deposits." The piece adds, "Demand for short-​term government debt instruments has risen this year as the supply of Treasury bills fell due to reduced government sales, causing money market rates to trade below zero. The Fed has kept its benchmark rate for overnight loans at near zero percent since 2008 and purchased assets to lower long- term rates. During the six-​week period ended Sept. 20, money-​market mutual funds took in $​66 billion, according to research firm Crane Data LLC, based in Westborough, Massachusetts. Total assets in the funds rose to $​2.​59 trillion, including $​2.​3 trillion in taxable and $​1.​46 trillion in prime funds."

Bloomberg writes "​Euro Crisis Makes Fed Lender of Only Resort as Funding Dries Up". The article says, "The Federal Reserve, chastised by Congress for lending money to foreign institutions such as the Central Bank of Libya, is once again the lender of last resort for banks around the world it knows little about. Three years after the collapse of Lehman Brothers Holdings Inc., money-​market borrowing rates for dollars are rising, leading the Fed and European Central Bank to make the currency available to Europe'​s institutions for as many as three months. U.​S. prime money-​market funds cut their exposure to euro-​zone bank deposits and commercial paper, or short-​term IOUs, to $​214 billion in August from $​391 billion at the end of last year, according to JPMorgan Chase & Co. data. The failure of regulators worldwide to address European banks’ fragile dependence on short-​term funding is "​putting the Fed in a really awkward position," said Karen Shaw Petrou, managing partner at Federal Financial Analytics, a Washington regulatory research firm whose clients include the biggest U.​S. banks. The swaps with Europe "​are an extremely advantageous political football" for critics of the Fed." See also, WSJ'​s "​For Some Companies, No Interest In Interest", which says, "​A little-​noticed provision of last year'​s financial-​overhaul law gave companies something they had long wanted: a way to earn interest on large balances held in bank checking accounts. But now, with the economy weak and interest rates tumbling, many of them don'​t want it anymore."

The Federal Reserve Bank of New York posts "​FAQs: Maturity Extension Program". It asks and explains, "Why is the Desk purchasing longer-​dated Treasury securities and selling shorter-​dated Treasury securities On September 21, 2011, the Federal Open Market Committee (​FOMC) directed the Open Market Trading Desk at the Federal Reserve Bank of New York (​the Desk) to purchase, by the end of June 2012, $​400 billion in par value of Treasury securities with remaining maturities of 6 years to 30 years and to sell, over the same period, an equal par value of Treasury securities with remaining maturities of 3 years or less. This policy step should put downward pressure on long-​term interest rates and help make financial conditions more accommodative. In doing so, this action will support a stronger economic recovery and help ensure that inflation over time is at levels consistent with the Federal Reserve'​s mandate to foster maximum employment and price stability.... Additional information on the effects of the program can be found at http://​www.​federalreserve.​gov/​monetarypolicy/​maturityextensionprogram.​htm.... What Treasury securities will the Desk sell? The Desk will sell nominal Treasury securities and TIPS that, as of the date of each sale operation, have remaining maturities of 3 months to 3 years. Securities with less than 3 months to maturity as of the date of a sale operation will not be sold in order to provide markets with greater certainty about the maturity profile of the SOMA'​s Treasury holdings."

Dow Jones writes "​Former Fed Chairman Volcker:​Money-​Market Funds Need More Oversight". The brief article says, "Former Federal Reserve Chairman Paul Volcker warned Friday that money-​market mutual funds are vulnerable to "​disturbing runs" in troubled times and are adding to the problems of European banks. Volcker said the funds are adding to the European debt crisis by withdrawing investment from European banks." It quotes Volcker in remarks prepared for an International Monetary Fund meeting Friday night, "​Money market funds today have trillions of dollars heavily invested in short-​term commercial paper, bank deposits, and notably recently, European banks. Without the backstop of official liquidity, they are actively withdrawing those funds, adding to the strains on European banking stability.... The time has clearly come to harness money market funds in a manner that recognizes both their structural importance in diverting funds from regulated banks and their destabilizing potential." Dow Jones adds, "​Volcker said that money-​market funds are "​truly hidden in the shadows of banking markets" and divert money from deposits in the regulated banking system. Volcker said that the funds need to be regulated like ordinary mutual funds." See also, FT'​s "​BNP Paribas rules out external help".

ICI'​s weekly "​Money Market Mutual Fund Assets" says, "Total money market mutual fund assets decreased by $​11.​82 billion to $​2.​621 trillion for the week ended Wednesday, September 21, the Investment Company Institute reported today. Taxable government funds increased by $​8.​57 billion, taxable non-​government funds decreased by $​18.​04 billion, and tax-​exempt funds decreased by $​2.​34 billion. Assets of retail money market funds increased by $​1.​42 billion to $​940.​45 billion. Taxable government money market fund assets in the retail category increased by $​1.​04 billion to $​193.​80 billion, taxable non-​government money market fund assets increased by $​930 million to $​553.​55 billion, and tax-​exempt fund assets decreased by $​550 million to $​193.​10 billion. Assets of institutional money market funds decreased by $​13.​24 billion to $​1.​681 trillion. Among institutional funds, taxable government money market fund assets increased by $​7.​53 billion to $​670.​98 billion, taxable non-​government money market fund assets decreased by $​18.​98 billion to $​911.​53 billion, and tax-​exempt fund assets decreased by $​1.​79 billion to $​98.​21 billion." Retail assets represent 35.​9% of all money fund assets vs. 64.​1%. Non-​government (​prime) assets represent 55.​9% of the total, Government assets (​including Treasury funds) represent 33.​0%, and Tax-​Exempt assets represent 11.​1% of total money fund assets. Year-​to-​date, money market fund assets have declined by $​189 billion, or 6.​7%.

Moody'​s Investor'​s Service issued a number of ratings releases yesterday, including: "Moody'​s downgrades Bank of America Corp. to Baa1/​P-​2; Bank of America N.​A. to A2, P-​1 affirmed," "Moody'​s downgrades Citigroup Inc to P-​2; Citibank Prime-​1 affirmed; all long-​term senior ratings confirmed," and "Moody'​s downgrades Wells Fargo & Company rating (​sr to A2); P-​1 affirmed." The first release says, "Moody'​s Investors Service has downgraded the ratings of Bank of America Corporation'​s (​BAC) holding company to Baa1 from A2 for long-​term senior debt and to Prime-​2 from Prime-​1 for short-​term debt. The long-​term deposit ratings of Bank of America N.​A. (​BANA) were downgraded to A2 from Aa3, while BANA'​s short-​term rating was affirmed at Prime-​1. The actions conclude a review for downgrade announced on June 2, 2011. The outlook on the long-​term senior ratings remains negative." (​Note that Crane Data'​s latest Money Fund Portfolio Holdings show that BANA is a much larger issuer in the short-​term market, accounting for over 63% of the total BofA issuance.) The Citi release says, "`​Moody'​s Investors Service confirmed the A3 long-​term rating of Citigroup and the A1 long-​term and Prime-​1 short-​term ratings of Citibank N.​A. At the same time, Moody'​s downgraded the short-​term rating of Citigroup (​the holding company) to Prime-​2 from Prime-​1." While these moves shouldn'​t have a dramatic impact on funds due to their partial nature (​the banks can shift issuance to the top-​rated portion), we will examine this in more detail in coming days.

The Preliminary Agenda for the 2nd annual Crane'​s Money Fund University was posted on the conference website (​www.​moneyfunduniversity.​com) earlier this week. Crane'​s Money Fund University, an affordable and comprehensive two day, "​basic training" course on money market mutual funds, will he held January 19-​20, 2012, at The Hyatt Regency Boston. Last year'​s inaugural University attracted over 100 speakers, sponsors and attendees, and we expect even a stronger showing this coming year. MFU covers the history of money funds, interest rates, Rule 2a-​7, ratings, rankings, money market instruments such as commercial paper and repo, and portfolio construction and credit analysis. (Click here for the full agenda.) New portfolio managers, analysts, investors, issuers, service providers, and anyone interested in expanding their knowledge of "​cash" investing should benefit from our comprehensive program. Even experienced professionals should enjoy a refresher course and the opportunity to interact with peers in an informal setting. Attendee registration for Crane'​s Money Fund University is $​500. Exhibit space is $​2,​000 and sponsorship opportunities are $​3K, $​4.​5K, and $​5K. E-​mail Pete to request the latest conference brochure. The 4th annual Crane'​s Money Fund Symposium, our larger flagship money market mutual fund event, is scheduled for June 20-​22, 2012, in Pittsburgh, Pa. (​Look for more details in coming weeks on www.​moneyfundsymposium.​com.)

Pensions & Investments writes "​Federated feels weight of rates, potential regs". The article says, "Federated Investors, the money market giant that sailed through the global financial crisis on a wave of safe-​haven inflows, is facing choppier waters this year because of rock-​bottom interest rates and potential changes to regulations governing money funds. The U.​S. Federal Reserve Board'​s Aug. 9 vote to keep short-​term rates between zero and 0.​25% through mid-​2013 was the latest rain on Federated'​s parade. Extremely low interest rates have left Federated waiving millions of dollars of fees on its money market funds -- which accounted for 76% of the firm'​s assets under management as of June 30 and almost half of its revenue -- to ensure a positive return for investors. In a recent interview, Christopher Donahue, president and CEO of Pittsburgh-​based Federated, conceded the Federal Reserve'​s recent pledge to keep rates low for another few years was '​not exactly a positive.' But he said the tough environment will pressure a growing number of smaller money market competitors to '​throw in the towel,' opening up continued '​roll-​up and acquisition opportunities' for Federated."

LA Times writes "​Bank deposits soar despite rock-​bottom interest rates". It says, "Americans are pumping money into bank accounts at a blistering pace this year, sending deposits to record levels near $​10 trillion on escalating fears that the U.​S. economy is on the verge of another implosion. There'​s no sign that the flood into checking, savings and money market accounts is slowing down. In the last three months, accounts at U.​S. commercial banks have increased $​429 billion, or 10%, almost double the increase for all of last year. There'​s one big problem: Banks don'​t want your money.... The Fed has pledged to hold short-​term rates near zero through mid-​2013 unless the economy improves as a way to combat the nation falling back into a recession. That'​s going to continue to cause pain to savers, and could force banks to become even more stringent about their intake of new deposits."

ICI'​s latest "​Money Market Mutual Fund Assets" report says, "Total money market mutual fund assets decreased by $​16.​45 billion to $​2.​633 trillion for the week ended Wednesday, September 14, the Investment Company Institute reported today. Taxable government funds decreased by $​3.​38 billion, taxable non-​government funds decreased by $​9.​98 billion, and tax-​exempt funds decreased by $​3.​09 billion. Assets of retail money market funds decreased by $​4.​84 billion to $​939.​03 billion. Taxable government money market fund assets in the retail category decreased by $​310 million to $​192.​76 billion, taxable non-​government money market fund assets decreased by $​3.​11 billion to $​552.​62 billion, and tax-​exempt fund assets decreased by $​1.​43 billion to $​193.​65 billion. Assets of institutional money market funds decreased by $​11.​61 billion to $​1.​694 trillion. Among institutional funds, taxable government money market fund assets decreased by $​3.​07 billion to $​663.​45 billion, taxable non-​government money market fund assets decreased by $​6.​87 billion to $​930.​51 billion, and tax-​exempt fund assets decreased by $​1.​67 billion to $​100.​00 billion." This latest decline follows two weeks of inflows. Month-​to-​date in Sept., money funds are now down $​4 billion. Year-​to-​date, money fund assets have declined by $​177 billion, or 6.​3%.

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"​Money market funds get boost from jittery investors" writes The Christian Science Monitor. It says, "Money market funds gained $​69 billion in August, while stock and bond funds lost $​32 billion. Besides money market funds, investors put $​1 billion into ETFs. Investors sought refuge from the market'​s volatility in August, withdrawing money from stock mutual funds and bond funds alike. The retreat from stock funds was unusually heavy for the third consecutive month, marking a renewed aversion to risk.... Money-​market funds: A net $​69 billion was deposited into these funds, designed to be safe harbors where investors can temporarily park cash and quickly access it when needed. That proved a strong draw in August, in contrast with July. In that month, investors withdrew a net $​113 billion, due to fears that Congress might fail to reach an agreement to lift the government'​s debt ceiling. Investors were scared off because nearly half of the $​2.​6 trillion that money funds hold is invested in Treasury bonds."

A press release entitled, "Bank of America Merrill Lynch Launches Enhanced Online Investment Access for Corporate and Commercial Clients," says, "Bank of America Merrill Lynch, a recognized leader in global treasury solutions, today announced significant enhancements to its online liquidity management and investment order capability. Corporate and commercial clients can now utilize CashPro Invest to enter orders and obtain information and reporting for U.​S. dollar denominated money market mutual funds and other short-​term investment products. Clients also now have access to extensive research available on money market mutual funds. CashPro Invest is integrated with CashPro Online, the bank'​s next-​generation treasury management portal, meaning clients have a one portal solution using a single sign-​on to navigate to virtually all of their treasury, credit and investment applications." Fred Berretta, Global Liquidity Investment Solutions executive for Bank of America Merrill Lynch, says, "Through CashPro Invest, our clients can quickly and easily enter money market mutual fund and other short-​term orders online with streamlined navigation and robust security features. They can also manage orders within their own company defined investment policy rules. In addition, they have fast and flexible access to virtually all of their investment account information as well as a significant amount of mutual fund research, all from one online location." The release adds, "CashPro Invest will eventually replace two existing Bank of America Merrill Lynch online investment applications, Connection and MoneyMarkets Express."

NY Times writes "​Wary Investors Start to Shun European Banks". It says, "When a $​225 million loan to BNP Paribas comes due Thursday at Legg Mason'​s Western Asset management unit, managers at its money market funds will be exercising caution. Instead of renewing the loan as they would have as recently as two months ago, they are looking to park investors' money elsewhere, avoiding BNP and other Continental banks in favor of institutions in Scandinavia, Canada and Britain.... In August, American money funds and other suppliers of short-​term credit chose not to refinance roughly $​50 billion of debt issued by European banks, a drop of 14 percent, according to JPMorgan research." The piece adds, "At Fidelity, which manages a total of $​428 billion, Adam Banker, a spokesman, said, "​We'​re very comfortable with our money market funds' European bank holdings, including French bank holdings."" See also, Bloomberg'​s "​Europe Stress Seen in Rates on Commercial Paper: Credit Markets".

Wells' latest monthly "​Overview, strategy, and outlook" says, "Negative rates on U.​S. Treasury bills (​T-​bills) are already not unusual -- for reasons that are perhaps more technical in nature -- and are discussed in more detail in the '​Strategies for the U.​S. government funds' section. We have also seen Treasury repurchase agreement (​repo) rates go negative from time to time, though large volumes have not traded at those levels. If the Fed eliminates the IOER, it is possible that we could see negative repo rates become more common, and other rates might follow, moving us from a ZIRP to a NIRP.... `​Does it make sense that investors would actually pay to invest money? Ordinarily, one would say no; investors won'​t assume the counterparty and settlement risk to earn less than zero, but it depends on their alternatives. If the only alternative that maintains a relatively constant value and offers immediate liquidity is a bank deposit for which they are charged a fee, then if the negative rate is cheaper than the fee to the bank, it does make sense."

The latest "​Money Market Mutual Fund Assets" report says, "Total money market mutual fund assets increased by $​6.​87 billion to $​2.​644 trillion for the week ended Wednesday, September 7, the Investment Company Institute reported today. Taxable government funds increased by $​440 million, taxable non-​government funds increased by $​4.​66 billion, and tax-​exempt funds increased by $​1.​76 billion. Assets of retail money market funds decreased by $​1.​23 billion to $​943.​57 billion. Taxable government money market fund assets in the retail category decreased by $​250 million to $​192.​76 billion, taxable non-​government money market fund assets decreased by $​2.​05 billion to $​555.​73 billion, and tax-​exempt fund assets increased by $​1.​07 billion to $​195.​08 billion. Assets of institutional money market funds increased by $​8.​10 billion to $​1.​700 trillion. Among institutional funds, taxable government money market fund assets increased by $​690 million to $​665.​90 billion, taxable non-​government money market fund assets increased by $​6.​72 billion to $​932.​82 billion, and tax-​exempt fund assets increased by $​690 million to $​101.​59 billion." Assets have increased for the 4th week in the past 5, brining their YTD decline down to $​156 billion, or 5.​9%. Crane Data'​s latest Money Fund Intelligence shows that money fund assets rose by $​58.​2 billion in August 2011, the largest increase since January 2009.

The Federal Reserve has posted an FAQ on "​Why are interest rates being kept at a low level?" It says, "The financial crisis that began in 2007 was the most intense period of global financial strains since the Great Depression, and it led to one of the deepest and most prolonged global economic downturns in history. The Federal Reserve took extraordinary actions in response to the financial crisis in order to help stabilize the U.​S. economy and financial system. These actions included reducing the level of short-​term interest rates to near zero. To provide further support for the U.​S. economy, the Federal Reserve has purchased large quantities of longer-​term Treasury and other high-​quality securities in an effort to further reduce longer-​term interest rates. Low interest rates help households and businesses finance new spending and help keep the prices of many other assets, such as stocks and houses, steady. By law, the Federal Reserve conducts policy to achieve its dual mandate of maximum employment and stable prices. Although the economic outlook is much improved from the period of the crisis, the unemployment rate remains high and underlying inflation is somewhat low. In this environment, the Federal Reserve has determined that an accommodative stance of policy with low interest rates is necessary to help promote a stronger pace of economic recovery and to help ensure that underlying inflation does not move even lower over the medium term."

A statement entitled, "​Euro, sovereign debt, liquidity and other issues: questions and answers from BNP Paribas" says, "How likely is it that the current crisis could lead to a freezing up of money markets and overnight interbank lending, similar to what we experienced during the Lehman crisis? Are you well-​equipped and sufficiently liquid to deal with such an adverse scenario? The situation today is very different. Among the large European banks, the fall in activity in the interbank market is not mainly due to counterparty risk issues, but to the banks pre-​empting the impact of the future Basel liquidity regulation. The interbank market is therefore likely to focus on instruments of one-​month duration or less, which is in line with what BNP Paribas had expected. Regarding BNP Paribas' funding position: BNP Paribas has access to substantial short-​term euro funding from a wide spread of sources. Conditions and maturities have not significantly changed in recent weeks. There has been no shortage of funds and no change in counterparties. In USD, we have an excess of short-​term liquidity which the bank is obliged to deposit at the Fed. BNP Paribas has been taking steps since the start of 2011 to secure its funding position by proactively increasing the duration of its short term resources (​one month to three months, three months to six months and so on). Despite the lower level of funding available to European banks from US money market funds in August, BNP Paribas has been able to tap a wide variety of funding sources. For example, US dollar funds have been sourced from corporates, supras, institutionals, Central Banks, wealth management clients, as well as money market funds across four geographic areas (​USA, Asia-​Pacific, Gulf countries, Western Europe). The bank has also had recourse to foreign exchange swaps to maintain access to US dollar funds. The recourse to alternative US dollar funding sources has had cost implications which have impacted pricing. In addition, BNP Paribas has a sizeable liquidity buffer: BNP Paribas has around E150bn of unencumbered assets eligible as collateral with central banks, of which USD30bn eligible under US Federal Reserve criteria."

The Financial Times writes "​US money market blow for eurozone". It says, "US money market funds say they cut their exposure to eurozone banks for a second consecutive month in August, reducing the availability of credit as the stress in the region'​s banking system increasingly affects stronger countries such as France. Some money market funds, historically essential providers of short-​term financing to European banks, have begun to avoid French institutions entirely, while other money market fund managers say they are "​de-​emphasising" the country'​s banks. One head described the process as the "ongoing diversification out of core Europe into the Nordic, Canadian and Japanese banks", adding that money market lending to banks in the peripheral countries, and to Spain and Italy, had in effect ceased." The FT quotes Peter Yi, director of short-​term fixed income at Northern Trust, "Exposures have fallen dramatically, even from a month ago." The FT added, "In a presentation to debt investors last week, Societe Generale reported that its short-​term funding dropped E19bn ($​27bn) to E53bn in the first half of August as money market funds pulled back. The bank also described its short-​term funding sources as '​well diversified', with abundant forms of euro-​based liquidity available."

MarketWatch writes "​FSB to scrutinize '​shadow banking' system". The article (​from London) says, "The Financial Stability Board said Thursday it will focus on money-​market funds, securitizations and securities lending and repos more as it tackles the problem of regulating the so-​called shadow banking system. The FSB has a mandate from the Group of 20 leading industrialized and emerging economies to draft recommendations on reforming the financial sector worldwide to avoid a recurrence of the 2008 financial crisis. Regulators are afraid that banks will simply outsource excessive risk-​taking to such "​shadow banks", now that they have raised the cost of risk-​taking with the new banking rules on capital and liquidity, which were finalized last year by the Basel Committee for Banking Supervision.... The FSB said it intends to propose policy recommendations on most of the above by July 2012. The sole exception was securities lending and repos, where recommendations will be drafted by the end of next year." See also, the Financial Stability Board'​s press release and Reuters' "​G20 task force steps up work on shadow bank rules", which says, "The Institutional Money Market Funds Association rejected the FSB'​s description of money market funds as shadow banks." Reuters quotes IMMFA Chairman Travis Barker, "​The only thing they share in common with a bank is that they transform liquidity, but they do so on a tiny scale and subject to rigorous constraints."

"​Fitch Assigns Rating to Wells Fargo Advantage National Tax-​Free Money Market Fund" says a press release. It explains, "Fitch Ratings has assigned the following rating to a tax exempt money market fund managed by Wells Fargo Funds Management, LLC. (​WFFM) --​Wells Fargo Advantage National Tax Free Money Market Fund '​AAAmmf'. The assigned '​AAAmmf' rating reflects the fund'​s extremely strong capacity to achieve its investment objective of preserving capital and providing shareholder liquidity through limiting credit, market and liquidity risks. The main drivers of the '​AAAmmf' rating are the credit quality, diversification, and liquidity of the portfolio assets and the capabilities and resources of WFFM as investment advisor. As of Aug. 18, 2011, the fund had approximately $​4.​5 billion in total assets under management. The Wells Fargo Advantage National Tax Free Money Market Fund seeks current income exempt from federal income tax, while preserving capital and liquidity. The fund pursues its investment objectives by investing in a portfolio of high-​quality, short-​term municipal obligations that are issued by or on behalf of states, territories and possessions of the U.​S. or their political subdivisions and financing authorities. These investments may have fixed, floating, or variable rates of interest, and typically include variable rate demand notes (​VRDNs) putable to a third party financial institution in seven days or less, or other municipal bonds/​notes. At least 80% of the Fund'​s net assets are invested in municipal obligations that pay interest exempt from federal income tax and federal alternative minimum tax (​AMT). Consistent with Fitch'​s '​AAAmmf' rating criteria, the fund maintains a high credit quality by investing exclusively in securities rated at least '​A/​F1' or equivalent."

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