A press release entitled, "Goldman Sachs Asset Management Updates Risk Management Platform," says, "Goldman Sachs Asset Management announced today the launch of the new "​Fund Tracker" feature, the latest addition to its suite of Risk Management solutions on the Goldman Sachs Global Liquidity Services Portal. This launch signifies GSAM'​s continued commitment to provide its clients with heightened transparency and risk management tools. GSAM has enhanced its global, multi-​fund family online liquidity tool with the "​Fund Tracker," a feature that aims to help corporate treasurers and banks better evaluate funds in a changing regulatory environment. In July 2014, the Securities and Exchange Commission announced new rules regulating money market mutual funds. Under the new rules, institutional prime funds will be required to float their daily Net Asset Values and all funds other than government funds must have liquidity fee and redemption gate features that can be implemented at certain liquidity levels. All funds will be required to increase transparency into their portfolios through more frequent holdings disclosure. While the new fund regulations do not change the risk profile or minimum investment requirements of money market funds, they do introduce new fund features and additional portfolio information that money market fund investors may take interest in monitoring and understanding in greater detail than in the past. The "​Fund Tracker" offers a deeper look into money market fund metrics that hold increased importance as investors prepare for implementation of the new rules, such as funds' market value NAVs and daily and weekly liquidity levels. Clients can view these data points in the context of other fund analytics, such as portfolio assets, interest rate risk measures, and performance. Visual analytics, insights from GSAM portfolio managers, and proactive notifications are all features aimed to equip multinational corporations and financial intermediaries to understand funds' positioning today so they can be better prepared for implementation of the new regulatory changes." Kathleen Hughes, Managing Director and Head of the Global Liquidity Sales team, comments, "​Leveraging over 30 years of experience managing risk in money market funds, GSAM continues to help corporate treasurers better understand their portfolios. This is another tool we are providing clients in response to feedback that they wanted a more centralized and consistent way to see risk exposures and monitor fund metrics. Investors have many questions about how regulatory reform will affect them. With these added metrics, and new original, written content, we hope to better guide institutional investors in this ever-​changing investment landscape."

On Wednesday, the Federal Reserve Bank of New York issued yet another "Statement Regarding Reverse Repurchase Agreements." The latest reads, "As noted in the October 19, 2009 Statement Regarding Reverse Repurchase Agreements, the Open Market Trading Desk (​the Desk) at the Federal Reserve Bank of New York (​New York Fed) has been working internally and with market participants on operational aspects of tri-​party reverse repurchase agreements (​RRPs) to ensure that this tool will be ready to support the monetary policy objectives of the Federal Open Market Committee (​FOMC). These operations do not represent a change in the stance of monetary policy, and no inference should be drawn about the timing of any change in the stance of monetary policy in the future. The New York Fed has been conducting daily, overnight RRP operations as part of an operational readiness exercise. Pursuant to an authorization from the FOMC to modify the offering rate of these operations, the Desk intends to adjust the offering rate." For operations conducted October 30 to October 31, the offering rate is 5 basis points; for operations conducted November 3 to November 14, the offering rate is 3 basis points; for operations conducted November 17 to November 28, the offering rate is 7 basis points; for operations conducted December 1 to December 12, the offering rate is 10 basis points; for operations conducted December 15 and after, the offering rate is 5 basis points. The release continues, "​All other terms of the exercise will remain the same. Any future changes to these operations will be announced with at least one business day'​s prior notice on the New York Fed'​s website. The Federal Reserve continues to enhance operational readiness and increase its understanding of the impact of RRPs through technical exercises. In further support of its objectives, the FOMC instructed the Desk to examine how term RRP operations might work as a supplementary tool to help control the federal funds rate, particularly when there are significant and transitory shifts in money market activity. In support of this goal, and to reduce potential volatility in money market rates, the FOMC instructed the Desk to conduct term RRP operations that cross year-​end. The operations will mature on or about January 2, 2015. The operations will be open to all eligible RRP counterparties and will use Treasury collateral. The Desk intends to offer the operations via auction at various times in December. No more than $​300 billion in term RRP transactions will be outstanding at any given time. This limit is in addition to the limit on overnight reverse repurchase agreements, which remain subject to a separate overall size limit of $​300 billion per day. The Desk will release further information about these term RRP operations by early December." See also, Reuters' "​Fed to launch longer-​term reverse repos test in December".

Fitch Ratings sent out a release entitled, "US Money Funds May Benefit from Market Illiquidity," which says, "US money funds may benefit from inflows as investors increase their structural cash allocations in response to lower market liquidity.... Between Sept. 15 and Oct. 15, the VIX index, an indicator of market volatility, nearly doubled, while US money fund assets grew by $​37.​9 billion (​1.​5%), driven by flows into institutional government money funds. While these flows in money fund assets may be explained by other factors, larger cash positions may represent a structural change in how portfolio managers react to changing liquidity, in addition to temporary defensive positioning in the face of the recent volatility.... While money funds face their own regulatory changes, they continue to be an efficient cash vehicle for investors, and may benefit from a shift to liquidity. Recent reforms introduced by the SEC mandate that institutional prime money funds float their net asset value (​NAV) starting in October 2016, while institutional government money funds will maintain a stable NAV. Some investors, particularly corporate treasurers, have indicated that these changes will likely cause them to shift some assets out of institutional prime money funds and into alternative liquidity products, including government money funds." Fitch also reports, "U.​S. Money Fund Reform Will Have an Uneven Impact on ABCP," which states, "Money fund reform'​s impact on asset-​backed commercial paper (​ABCP) programs will vary, depending on each program'​s investor base composition.... Investments in ABCP by institutional prime money funds are expected to decrease following the Securities and Exchange Commission'​s (​SEC) recent amendments to Rule 2a-​7. The SEC'​s changes will likely cause some outflows from institutional prime money funds, which have traditionally been large investors in ABCP. However, we expect outflows from money funds will take place gradually over the implementation period (​which will end in October 2016) and will likely be offset by inflows into new products that invest in ABCP. Fitch believes that the ABCP market will weather the reforms as other investors step in to replace money funds.... Estimates for potential outflows vary greatly, with the high end of the range at about 50% of institutional prime money fund assets, or approximately $​476 billion. Based on these funds' investments in ABCP, this could amount to about 13% of total ABCP outstandings as of July 2015, or $​32 billion.... At the same time, some of the money leaving institutional prime money funds is expected to migrate to products with similar investment mandates, reducing the likely impact of the outflows from money funds."

The Association for Financial Professionals Annual Conference is next week, November 2-​5, in Washington, D.​C. The country'​s largest corporate treasury event attracts almost all of the the major providers of institutional money funds and online trading "​portals". The description says that the event features "over 6,​500 treasury and finance professionals" and says, "Here are the top 6 reasons why you should attend the most important event for treasury and finance: 1. You'​ll bring back real solutions to the office with over 140+ educational sessions across 8 tracks; 2. Insights into the current global political upheaval with these highly distinguished speakers; 3. Build your professional network at events like the Welcome Reception and the Industry Roundtables Luncheon; 4. Make the most of time away from the office with pre-​conference seminars on targeted subjects; 5. Earn continuing education credits in just a few days; 6. Discover innovative products and solutions to streamline operations and cut costs in the Exhibit Hall." Several sessions involve money market funds and/​or cash investing. The keynote speakers include former Fed Chairman Ben Bernanke on November 2. Also, AFP'​s October 27 issue of its `​EconWatch newsletter says, "Companies sharply slowed their accumulation of cash during the 3rd quarter, pointing towards an improved corporate outlook in business conditions. These results suggest building confidence among U.​S. businesses during Q3. 34% of companies built out their cash balances during the quarter versus 28% that had shed cash during the 3 months. The difference of +​6 was down 6 points from the previous quarter'​s reading and off 13 points from the Q3 2013 survey results. 27% of organizations' cash balances at the end of Q3 2014 were larger than they were a year earlier, while 31% held smaller cash balances versus Q3 2013 levels. The difference of -​4 is 31 points below the previous quarter'​s reading, 25 points below the Q3 2013 reading and the lowest reading in the history of the data series." Finally, see AFP'​s article, "​How Will Basel III Impact Corporate Deposit Strategies?".

Reuters wrote "​Alibaba-​linked money market fund sees first decline" Friday. It said, "Yu'​e Bao, the online money market fund offered by an affiliate of Chinese e-​commerce giant Alibaba Group Holding Ltd, reported its first [​asset] decline since its launch last year, Chinese asset manager Tianhong Asset Management Co reported on Friday. Yu'​e Bao'​s net [​assets] decreased nearly 7 percent to 534.​89 billion yuan ($​87.​45 billion) in the third quarter from 574.​16 billion yuan ($​93.​87 billion) in the second quarter, as interest rates for interbank deposits declined. Easily accessible on smartphones, Yu'​e Bao is China'​s biggest money market fund in terms of assets under management. It started in June, 2013 as a partnership between fund manager Tianhong and Alibaba-​affiliated Alipay, China'​s biggest online payments platform. Alipay bought a majority stake in Tianhong in May. Alibaba last week changed the name of Alipay to Ant Financial Services Group as a major push into the financial services industry. Yu'​e Bao attracted 2.​5 million new users in the third quarter and had 149 million user accounts in total by the end of September." At $​87.​45 billion, Yu'​e Bao would be the fourth largest money market fund in the world behind U.​S. giants Vanguard Prime Money Market Fund (​VMMXX, $​131.​2 billion), Fidelity Cash Reserves (​FDRXX, $​115.​5B) and JPMorgan Prime MM Capital (​CJPXX, 104.​9b).

Money market fund bounced back this week as assets increased, according to ICI'​s latest "​Money Market Fund Assets" report. The release says, "Total money market fund assets increased by $​12.​82 billion to $​2.​62 trillion for the week ended Wednesday, October 22, the Investment Company Institute reported today. Among taxable money market funds, Treasury funds (​including agency and repo) increased by $​3.​75 billion and prime funds increased by $​9.​41 billion. Tax-​exempt money market funds decreased by $​340 million. Assets of retail money market funds increased by $​6.​64 billion to $​915.​36 billion. Among retail funds, Treasury money market fund assets increased by $​2.​76 billion to $​205.​10 billion, prime money market fund assets increased by $​3.​73 billion to $​524.​86 billion, and tax-​exempt fund assets increased by $​150 million to $​185.​41 billion. Assets of institutional money market funds increased by $​6.​17 billion to $​1.​71 trillion. Among institutional funds, Treasury money market fund assets increased by $​990 million to $​756.​19 billion, prime money market fund assets increased by $​5.​67 billion to $​880.​57 billion, and tax-​exempt fund assets decreased by $​490 million to $​69.​97 billion." The previous week, MMF assets dropped $​21.​9 billion. However, month to date through Oct. 22, money fund assets have increased $​73.​6 billion, according to Crane'​s Money Fund Intelligence Daily. In other news, the Boston Globe did a follow up article to their piece last Sunday "Fidelity fought Washington over money market funds -- and won." (​See our October 20 Link of the Day, "Globe on Fidelity MMF Lobbying.) In "Elizabeth Warren'​s Silence Was Fidelity'​s Gain," the Globe says, "In a statement to the Globe, Warren'​s office said the SEC rules were "​an important first step" and stressed a need to "​balance the risks that money market funds can pose to the economy against the need to maintain money market funds as an important investment alternative."

Pensions & Investments released its quarterly "Money Market Mutual Funds Most Used by DC Plans" late last month. It ranks the MMFs with the most assets in defined contribution plans as of June 30, 2014. The rankings are as follows: 1. Vanguard Prime Money Market-​Institutional ($​15.​4 billion); 2. Fidelity Retirement Money Market ($​12.​6 billion); 3. Fidelity Institutional MM Portfolio ($​8.​2 billion); 4. Vanguard Prime Money Market ($​6.​7 billion); 5. Fidelity Cash Reserves ($​6.​6 billion); 6. American Funds Money Market ($​4.​2 billion); 7. Wells Fargo Advantage Government ($​3.​7 billion); 8. Fidelity Retirement Government ($​3.​3 billion); 9. Wells Fargo Advantage Heritage ($​2.​9 billion); 10. Wells Fargo Advantage Cash Investment ($​2.​8 billion). In other news, the SEC adopted "​Credit Risk Retention Rules", which will impact the asset-​backed securities market, by a vote of 3-​2 on Wednesday. Said SEC Chair Mary Jo White in her statement commented, "Today, the Commission will consider the recommendation of the staff to adopt, jointly with five other federal agencies, final rules for the asset-​backed securities market that will require securitizers to keep "​skin in the game." Specifically, we will consider rules to require certain securitizers to retain no less than five percent of the credit risk of the assets they securitize." In his dissenting comments, Commissioner Daniel Gallagher said, "​The awfulness of today'​s rulemaking makes the oft-​discussed issue of GSE reform all the more important.... It is time for this Commission to declare that it is no longer willing to play the frog to the prudential regulators' scorpion. We are increasingly called upon to cross the river with them on our back by going along with their ideas, only to have them sting us halfway to the opposite shore, drowning us both." (​See Marketwatch'​s "​SEC'​s Gallagher Calls Regulators Scorpions".)

A press release earlier this month, entitled, "BNY Mellon to Acquire U.​S. Investment Manager to Cutwater Asset Manager," tells us, "BNY Mellon announced today that it has reached an agreement to acquire Cutwater Asset Management, a U.​S.-​based fixed income and solutions specialist with a 20-​year track record and approximately $​23 billion in assets under management. Located in Armonk, NY, the firm is currently a wholly-​owned subsidiary of MBIA Inc." The release continues, "Upon completion of the deal, Cutwater will operate as part of BNY Mellon Investment Management and will work closely with, and be administered by, Insight Investment. Insight is one of BNY Mellon'​s premier investment management boutiques and one of Europe'​s leading investment managers. The addition of Cutwater'​s capabilities will enhance BNY Mellon'​s and Insight'​s U.​S. platform and abilities to offer specialized fixed income solutions. Cutwater'​s products and investment solutions include a wide range of fixed income strategies such as core, long duration, high yield, loans and absolute return strategies." MBIA'​s Cutwater is known in the "​cash" business for managing Local Government Investment Pools, or LGIPs, including Connecticut Cooperative Liquid Assets Securities System Plus and New Hampshire Public Deposit Investment Pool. Curtis Arledge, CEO, BNY Mellon Investment Management, said, "Cutwater brings an impressive performance history, strong intellectual capital and an investment culture consistent with BNY Mellon'​s. Given the unprecedented interest in the fixed income market at this time, we are excited by the opportunity to expand our investment offerings for clients as a result of this combination of fixed income capabilities." For more on recent consolidation, mergers and acquisitions in the money market space, see our article "Rates, Reforms Driving Money Fund Consolidation, Changes" in the October issue of Money Fund Intelligence.

Moody'​s issued a report last week entitled, "Money Funds' Supply and Yield Will Suffer Further Amid Drop in Short-​Term Issuance by Banks Due to Basel III." It said, "Euro and Sterling money market funds have significantly reduced their exposure to financial institutions in recent years, offsetting the reduction mainly with government securities and reverse repurchase agreements (​repos), says Moody'​s Investors Service. "​With regulators pushing banks to reduce short-​term wholesale funding, and bank credit quality deteriorating due to the depressed global economic environment between 2009 and 2012, money funds have had to find alternative sources of investments," says Marina Cremonese, a Moody'​s assistant vice president and co-​author of the report. Euro MMFs' direct exposure to financial institutions has fallen to 54% of funds' assets under management in June 2014 from 75% in June 2010, while investments in government securities and repos have increased by 13% and 7%, respectively. Sterling MMFs have reduced their exposure to financial institutions to 72% in June 2014 from 82% in June 2010. For US MMFs, investments in financial institutions are roughly flat from four years ago. The shrinking investment supply has had a lesser impact on US MMFs as they started off with a lower exposure to financial institutions compared to Euro and Sterling MMFs, and they also benefited from the Fed'​s reverse repo facility. Moody'​s expects a further squeeze in the issuance of short-​term bank securities when Basel III rules are actually implemented starting in January 2015. As a consequence of the worsening supply/​demand imbalance, MMF managers will have to give up a few basis points of return in order to preserve diversification and the short maturity profile of their funds." In other news, on Friday the European Central Bank released the "Results of the Euro Money Market Survey 2014." The release explains, "The European Central Bank (​ECB) is publishing the results of the "​Euro Money Market Survey 2014", which highlights the main developments in the euro money market in the second quarter of 2014, comparing them with those in the second quarter of 2013."

Sunday'​s Boston Globe writes "​Fidelity fought Washington over money market funds -- and won". The article says of Fidelity CEO Abigail Johnson, "Her trip to meet with the SEC chief in June 2012 was part of an epic and unusually harsh lobbying battle waged by Fidelity and a handful of allies in the mutual fund industry. Their mission: stop the Obama administration'​s move in the aftermath of the financial crisis to rein in a huge and highly profitable part of their business, money market funds.... The SEC faced withering criticism as it tried to fortify money market funds -- which emerged as a surprising threat to the economy at the height of the crisis -- against future investor runs and potentially calamitous failures.... The story also offers a window into the public policy agenda of one of Boston'​s richest corporate sectors. Among mutual funds, Fidelity had the most to lose.... Ned Johnson made Fidelity an early pioneer in money market funds, which are low-​risk investments that offer small gains but are supposed to provide a stable and convenient place to park cash. He invented the concept of check-​writing for the funds in the 1970s, helping them become hugely popular with mom-​and-​pop investors across America. Today Fidelity manages by far the largest amount of assets in money market funds in the world, with $​410 billion. By charging just a tiny fraction of that massive sum in fees, it reaps about $​650 million in annual revenue.... Five years of trench warfare lurched to a close this year, in July, when the SEC issued final rules. It was billed as a compromise, but reformers said industry got the best of the deal. The "​floating" share price will be required, but only for funds that serve large institutional investors -- the category that experienced the biggest runs in 2008. The fixed $​1 share price will remain in place for funds open to small-​time, retail investors and for funds that invest in government and municipal debt. For Fidelity and others, it represented "​a qualified victory," said Marcus Stanley, policy director for Americans for Financial Reform, a nonprofit advocacy group that sought tougher action. "​They fought off a bunch of things that were much more problematic for them." At the time of passage, Mary Jo White, the former federal prosecutor and SEC chairwoman who replaced Schapiro, hailed the new rules as a "​strong reform package" that will reduce the risk of runs. `​Fidelity'​s head of fixed-​income, Nancy Prior, said the SEC struck "​a reasonable balance.""

Money fund assets broke a 3-​week streak of big asset gains as they dropped sharply in the latest week. ICI released its latest "Money Market Fund Assets" report, which showed total money market fund assets decreased by $​21.​95 billion to $​2.​61 trillion for the week ended October 15. The release says, "Among taxable money market funds, Treasury funds (​including agency and repo) decreased by $​2.​20 billion and prime funds decreased by $​18.​06 billion. Tax-​exempt money market funds decreased by $​1.​69 billion. Assets of retail money market funds decreased by $​620 million to $​908.​56 billion. Among retail funds, Treasury money market fund assets decreased by $​330 million to $​202.​34 billion, prime money market fund assets decreased by $​40 million to $​520.​96 billion, and tax-​exempt fund assets decreased by $​250 million to $​185.​25 billion. Assets of institutional money market funds decreased by $​21.​33 billion to $​1.​70 trillion. Among institutional funds, Treasury money market fund assets decreased by $​1.​87 billion to $​755.​20 billion, prime money market fund assets decreased by $​18.​02 billion to $​874.​90 billion, and tax-​exempt fund assets decreased by $​1.​44 billion to $​70.​45 billion." In other news, the Financial Times wrote "Investors Pour Billions into Money Funds in “​Dash for Cash." It says, "Ever since Mario Draghi introduced a negative deposit rate -- in effect charging banks who park their surplus funds at the European Central Bank -- it has been a tough time to be a money market fund manager.... But, while logic suggests return-​starved investors should shun assets that offer nil, or even sub-​zero, yields, MMFs now face a different conundrum: how to invest the billions flowing their way. Last week saw a record $​23.​46bn flow into European MMFs in spite of fears that rock-​bottom ECB rates would make it harder for them to make money, according to EPFR, the data provider."

FDIC-​insurance "​amalgamator" StoneCastle Cash Management is hosting a webinar on "Investment Policy Considerations & Amendments Post MMF Reform" Thursday (​10/​16) at 3:​00pm (​EDT). "The question every treasurer seems to be asking is, how will the recent SEC money fund rulings and pending impact of Basel III impact my short term cash strategy? More specifically, what steps should treasurers take now to ensure their Investment Policy Statement (​IPS) takes into consideration the new rules while providing flexibility to use other potential vehicles/​strategies. Potential topics for discussion include the current state of the market, an update on pending reform and timetable for implementation, implications of new regulations and what they mean for your Investment Policy Statement (​IPS), identification of potential, necessary amendments such as how do you account for a variable NAV money fund & how to introduce new cash-​management options on your IPS. Ted Howard of iTreasurer will moderate the webinar. Greg Fayvilevich of Fitch Ratings will offer insights from his report, "Why Money Fund Reform will have uneven Impact on Corporations," provide insights on the need for financial professionals to review/​update their investment policies, and introduce questions which every financial professional should be asking/​discussing in light of recent reforms. Brandon Semilof of StoneCastle will offer insights from financial professionals since announced reforms, what steps are being considered and potential strategies being discussed. Brian Leach of Pimco will offer insights on potential outlook for rates from the minds of PIMCO and introduce potential strategies and approaches for organizations' strategic/​longer term cash balances. The Panel discussion will be followed by a live Q&​A." Click here to register. In other news, Financial Sciences Corp., issued a press release "New Release of ATOM from Financial Sciences Delivers Enhanced Business Intelligence Tools and Expanded Functionality." It says, "​ATOM, Financial Sciences' integrated treasury management system (​TMS), brings together all aspects of global treasury operations, financial risk management, governance and compliance into one integrated web-​based solution.... This release offers enhanced business intelligence tools for complete visibility into cash and risk by providing a powerful set of management reporting dashboards, including charts, maps and tables with transaction level drilldown."

The Financial Stability Board issued a press release Tuesday announcing a new "Regulatory Framework for Haircuts on Non-​centrally Cleared Securities Financing Transactions." It says, "The Financial Stability Board (​FSB) is publishing today a "​Regulatory Framework for Haircuts on Non-​centrally Cleared Securities Financing Transaction." This Framework is a key part of the FSB'​s policy recommendations to address shadow banking risks in relation to securities financing transactions, and takes into account public responses received on the consultative proposals issued on 29 August 2013 as well as the results of a two-​stage quantitative impact study (​QIS). In revising the Framework, the FSB has decided to raise the levels of numerical haircut floors based on the QIS results, existing market and central bank haircuts, and data on historical price volatility of different asset classes. It has also decided to propose applying the numerical haircut floors to non-​bank-​to-​non-​bank transactions so as to ensure shadow banking activities are fully covered, to reduce the risk of regulatory arbitrage, and to maintain a level-​playing field.... The FSB will complete its work on the application of numerical haircut floors to non-​bank-​to-​non-​bank transactions and set out details of how it will monitor implementation by the second quarter of 2015. FSB member authorities will implement the Framework, including the numerical haircut floors, by the end of 2017." It continues, "Mark Carney, Chairman of the FSB, stated that "​The regulatory framework for haircuts on securities financing transactions issued by the FSB today addresses important sources of leverage and the level of risk-​taking in the core funding markets. It has been carefully developed, finalised after rounds of public consultation and impact studies, and marks a big step forward in the FSB'​s overall work programme to transform shadow banking into resilient market-​based financing conducted on a sound basis." Daniel Tarullo, Chairman of the FSB Standing Committee on Supervisory and Regulatory Cooperation stated that "​Securities financing transactions such as repos are important funding tools for a wide range of market participants, including non-​bank financial firms. The implementation of the numerical haircut floors on securities financing transactions will reduce the build-​up of excessive leverage and liquidity risk by non-​banks during peaks in the credit and economic cycle. It will be important for the FSB to monitor the impact of the framework following the implementation to help ensure that it achieves these objectives." Bloomberg writes in "Repo Traders Face FSB Collateral Rule in Shadow Bank Push," "Traders are facing new global rules on how they determine the value of collateral in repo transactions as regulators seek to prevent panic writedowns that are seen fueling future financial crises. The Financial Stability Board, a global group that brings together central bankers and government officials from the Group of 20 nations, today published a set of guidelines on discounts applied to collateral handed over as part of repurchase-​agreement trades and other securities-​financing transactions that aren'​t processed through clearing houses. It also set minimum standards for some types of trades." Also, the FT writes, "​Terms Laid Down for Taming Shadow Bank Risk."

The deadline to comment on the SEC'​s Proposed Rule, "Removal of Certain References to Credit Ratings and Amendment to the Issuer Diversification Requirement in the Money Market Fund Rule," is Wednesday, October 14. (​We covered the proposal in our August 5 "News", "SEC Proposal to Remove Credit Ratings Eliminates First, Second Tier.") Just one substantial recent comment has been posted so far (​there are plenty from 2011, when removing ratings from Rule 2a-​7 was first proposed). The new letter is from Amy Lancellota, managing director, Independent Directors Council. Lancellotta writes, "The Independent Directors Council appreciates the opportunity to provide comments on the Securities and Exchange Commission'​s re-​proposal to remove certain references to credit ratings in the money market fund rule. Although IDC had previously urged the Commission to retain the references to credit ratings, we recognize that the Commission is implementing a Congressional directive in the Dodd-​Frank Wall Street Reform and Consumer Protection Act (​Dodd-​Frank Act).... Given this mandate, IDC is generally supportive of the approach taken in the re-​proposal, which reflects comments raised by IDC and others on the initial proposal. Our specific comments are provided below." She continues, "​Under the Commission'​s initial proposal, in place of the requirement that eligible securities be rated or of comparable quality, a fund board (​or its delegate) would have been required to: (​1) determine whether securities are eligible securities based on minimal credit risks; and (​2) distinguish between first and second tier securities based on subjective standards (​e.​g., "​highest capacity to meet its short-​term financial obligations" for a first tier security). IDC and others expressed concern about the proposed approach and recommended eliminating the first and second tier categories and subjecting eligible securities to one uniform, very high standard. IDC and others also stated concern about the "​highest capacity" standard, which does not seem to contemplate a range of ratings. The re-​proposal responds to these concerns by eliminating the distinction between first and second tier securities and using the "​exceptionally strong capacity" standard. We support this approach."

Money market mutual fund assets have been on a tear the past two and a half months and past three weeks, rising by $​54.​8 billion the past 3 weeks and by $​76.​9 billion since July 30. They appear to be repeating their 2012 and 2013 pattern of rising sharply in the second half of the year after falling in the first half. ICI'​s latest "​Money Market Fund Assets" release says, "Total money market fund assets1 increased by $​16.​97 billion to $​2.​63 trillion for the week ended Wednesday, October 8, the Investment Company Institute reported today. Among taxable money market funds, Treasury funds (​including agency and repo) increased by $​1.​36 billion and prime funds increased by $​13.​74 billion. Tax-​exempt money market funds increased by $​1.​87 billion." It explains, "Assets of retail money market funds increased by $​6.​07 billion to $​909.​18 billion. Among retail funds, Treasury money market fund assets increased by $​2.​36 billion to $​202.​67 billion, prime money market fund assets increased by $​2.​65 billion to $​521.​01 billion, and tax-​exempt fund assets increased by $​1.​06 billion to $​185.​51 billion. Assets of institutional money market funds increased by $​10.​90 billion to $​1.​72 trillion. Among institutional funds, Treasury money market fund assets decreased by $​1.​00 billion to $​757.​07 billion, prime money market fund assets increased by $​11.​09 billion to $​892.​91 billion, and tax-​exempt fund assets increased by $​810 million to $​71.​89 billion." Year-​to-​date, money fund assets have declined by $​88 billion, or 3.​2%.

Simon Potter, executive vice president of the Federal Reserve Bank of New York spoke Tuesday on "Interest Rate Control during Normalization," and recent changes to the Overnight RRP test exercise. He said, "​To further examine how ON RRPs might best be structured to supplement IOER in controlling the fed funds rate while limiting the potential for unintended effects in financial markets, the FOMC recently directed the Desk to make several changes to the design of its ON RRP operations. In particular, as of September 22, the maximum bid limit per counterparty was raised from $​10 billion to $​30 billion, an overall size limit of $​300 billion per operation was imposed, and an auction process was introduced to determine the interest rate on the operation and allocate take-​up when the sum of bids exceeds the new $​300 billion limit. The $​30 billion individual bid limit was informed by evidence on the desired investments of counterparties that had bid at the previous maximum of $​10 billion, and it took into account the size of assets under management of our counterparties. For almost all counterparties, the $​30 billion limit is unlikely to be binding in any circumstances. The $​300 billion overall limit was above total demand observed over the first year of testing, with the exception of the operation conducted at the end of the second quarter of this year." He continued, "So what are the benefits of moving from a structure with individual caps alone to one with an aggregate cap as well? One benefit is that, in limiting the overall take-​up but not individual take-​up, an aggregate cap should produce a more efficient allocation of usage among counterparties than would a system of individual caps. Further, an aggregate cap should better balance efficient control of money market rates under normal conditions with the risk of a destabilizing surge in use of the facility in times of stress. The reduced risk of a surge in use in a system with an aggregate cap comes from the fact that take-​up across counterparties is not perfectly correlated. As a result, an aggregate cap that binds at some frequency can be set below the sum of individual caps that would bind for at least one of the counterparties at the same frequency.... The Federal Reserve has been closely analyzing the results of the ON RRP operations conducted under these new testing parameters in order to further its understanding of how an ON RRP facility should be structured during the normalization process. As many market participants anticipated the aggregate cap did bind on quarter end. The auction procedure went smoothly and while rates did trade soft on the quarter end, this was only a temporary phenomenon and there was no evidence of market disruption from the unfilled bids at the auction." The Wall Street Journal also covered his speech in, "N.​Y. Fed'​s Simon Potter: Reverse Repos Effective in Setting Rate Floor." Finally, the Fed released the Minutes from its Sept. 16-​17 FOMC meeting, saying, "Participants agreed to consider potential additional revisions to the ON RRP exercise at future FOMC meetings."

On Wall Street wrote Tuesday, "Repo Pullback Impacts Money Market Funds." The article says, "New capital and liquidity rules are forcing banks to pull back from a vibrant market that has allowed them access to inexpensive overnight funding. With the decline in funding volumes come potential outcomes that impact the $​2.​591 trillion market for money market mutual funds. "There are ripple effects," says Joseph Abate, a money market strategist at Barclays PLC in New York. "The first ripple effect is there is a significant shortage of safe assets for cash-​long investors to buy." During the past two years, banks have been steadily reducing the volume of repurchase agreements, known as repos, that have served as a significant source of liquidity but which regulators see as an unreliable funding source for banks during crisis periods. In this situation, money market funds may find themselves scrambling to find enough repo, which forces the funds to use an overnight reverse repo facility run by the Fed. This also keeps interest rates down on bills and other short-​duration instruments as well. "​That may or may not be a bad thing. However, it does create a disconnect in the market," says Abate." The piece continues, "It'​s been a long, steady and substantial 20% slide in repo activity from the recent peak of $​2.​18 trillion in the collateral value of repos in November 2012 to $​1.​74 trillion in July 2014, according to the Federal Reserve Bank of New York -- with more likely to come. The implementation of new Basel III regulations is expected to put further downward pressure on the repo market. Since the regulators first proposed a supplemental leverage ratio for the largest banks last summer, the repo market has declined by $​750 billion as of July 2014, according to estimates from Goldman Sachs. Though the new leverage ratio will not go into effect until January 2018, Tier 1 leverage capital becomes a binding constraint under the Fed'​s annual stress tests of major banks beginning next year. As a result, the drawback from the repo market by banks is likely to be permanent, according to a research note published in April by Goldman Sachs."

The Financial Times published, "SEC'​s New Rules Gives US Money Market Funds a Floating Feeling," a basic overview of new MMF regulations written by Robert Pozen and Theresa Hammacher. It reads, "The rules will have the biggest impact on money market funds serving institutional investors, which will have to move from a constant to a floating net asset value. The rules will also put pressure on most institutional and retail money market funds to impose liquidity fees and suspend redemptions during financial crises. But neither set of rules will apply to money market funds holding 99.​5 per cent or more of government securities. Thus, the two critical questions are what constitutes a government security, and what differentiates an institutional from a retail money market fund? The rules narrowly define governmental securities to include cash, US Treasuries and securities issued by US federal agencies. Notably, for this purpose, government securities do not include securities issued by state or city governments -- the assets held by most tax-​exempt money market funds." It continues, "In short, the new rules are likely to reduce the chances of runs on money market funds in times of financial crisis. But it remains to be seen whether these tougher requirements will diminish the appeal of the funds relative to bank deposits for short-​term investors." In other news, Federated CIO Debbie Cunningham released her monthly commentary. "A little over two months ago, cash management in this country was hindered by new rules that the Securities and Exchange Commission issued for institutional prime and institutional municipal money-​market funds. Last month, it was the Federal Reserve'​s turn.... But only a few months into that process, the Fed announced that it was changing one of its programs that has actually been helpful to the cash-​management industry. Since September 2013, the New York Fed has run an overnight reverse repo program for certain large counterparties, with Treasuries as collateral. After some experimentation, since early 2014 it had settled on offering five basis points daily to fund this facility. While not much, at least it provided a floor to money-​market trading. As the majority of the market was focused on tightening and tapering in the Federal Open Market Committee release mid-​September, we were also dealing with different news. The New York Fed simultaneously announced that the entire ON RRP would be restricted to $​300 billion nightly and that a five basis point floor would no longer be guaranteed -- essentially destroying its main goal of helping money funds in this time of its extraordinary accommodative policy. The new process could hardly be more needlessly complicated."

Fitch Ratings wrote Friday, "U.​S. Money Funds Well-​Positioned for Gradual or Sharp Interest Rate Rises." The brief says, "U.​S. money market funds are well-​positioned to manage risks associated with rising interest rates, either a modest rise or a sharper rise accompanied by weaker economic conditions, according to Fitch Ratings. As noted in a recent report on interest rates, Fitch'​s base case scenario assumes the completion of the Fed'​s tapering program, strengthening world economic growth over 2014-​2016 and a gradual tightening of monetary policy over the next 12 months. Fitch'​s stress case scenario involves a sharper hike of interest rates amid weakening or stagnant economic growth, among other factors. U.​S. money funds have recently begun adjusting their portfolios in anticipation of rising interest rates, with prime funds lowering their weighted-​average maturities (​WAM) to an average of 42 days. Regulatory rules and Fitch'​s rating criteria constrain money funds' WAMs to limit exposure to interest rate risk. The current limit means that a money fund portfolio with a 60 day WAM can withstand an instantaneous 3% interest rate increase before '​breaking the buck', all else being equal. Fitch notes that there is considerable variability among funds with regard to their current WAM positioning and portfolio strategies in a rising rate environment. Approximately 36% of money funds have WAMs between 41 and 50 days, while only 17% of funds operate with WAMs greater than 50 days. The full report is available at www.​fitchratings.​com. This is part of a series of reports by Fitch looking at interest rate sensitivities across various U.​S. analytical sectors." In other news, see Reuters published "​Money market inflows jump in latest week - Lipper", which says the large amount of inflows into money market funds last week may be partly attributable to investors fleeing PIMCO bond funds for MMFs. Writes Lipper, "Investors in U.​S.-​based funds poured a net $​18.​9 billion into money market funds in the latest week, double the previous week'​s amount, amid record withdrawals from Pimco'​s flagship fund previously run by Bill Gross.... Much of that cash surge is likely money that rushed out of Pimco after the Gross shock, said Patrick Keon, a research analyst with Lipper. "​I think that the money markets category is a good bet for the bulk of that money" coming out of Pimco, he said. It'​s possible that investors are "​parking the money in money market funds until they do more research," he said." (​Note: Crane Data doesn'​t believe that PIMCO flows were a major factor in last week'​s asset jump, since the money fund increases.)

The ICI released its latest "Money Market Fund Assets" report, which says, "Total money market fund assets increased by $​22.​8 billion to $​2.​61 trillion for the week ended October 1." This was the largest increase of 2014 and the first time assets have been above $​2.​6 trillion since early April 2014. ICI'​s release explains, "Among taxable money market funds, Treasury funds (​including agency and repo) increased by $​28.​56 billion and prime funds decreased by $​6.​52 billion. Tax-​exempt money market funds increased by $​810 million. Assets of retail money market funds increased by $​2.​41 billion to $​903.​11 billion. Among retail funds, Treasury money market fund assets increased by $​740 million to $​200.​31 billion, prime money market fund assets increased by $​2.​14 billion to $​518.​35 billion, and tax-​exempt fund assets decreased by $​470 million to $​184.​44 billion. Assets of institutional money market funds increased by $​20.​42 billion to $​1.​71 trillion. Among institutional funds, Treasury money market fund assets increased by $​27.​82 billion to $​758.​07 billion, prime money market fund assets decreased by $​8.​67 billion to $​881.​82 billion, and tax-​exempt fund assets increased by $​1.​28 billion to $​71.​09 billion." In other news, the International Monetary Fund (​IMF) published a report entitled, "Shadow Banking Is Boon, Bane for Financial System." It says, "​Shadow banks act similarly to regular banks by taking money from investors and lending it to borrowers, but are not governed by the same rules or supervised. Shadow banks can include financial institutions such as money market mutual funds, hedge funds, finance companies, and broker/​dealers, among others. The IMF'​s latest Global Financial Stability Report analyzes the growth in shadow banking in recent years in both advanced and emerging market economies and the risks involved. According to the report, shadow banking amounts to between 15 and 25 trillion dollars in the United States, between 13.​5 and 22.​5 trillion in the euro area, and between 2.​5 and 6 trillion in Japan. "​We found that the same factors often seem to drive the growth of shadow banking across countries," says Gaston Gelos, chief of the Global Financial Analysis Division at the IMF. "Shadow banking tends to take off when strict banking regulations are in place, which leads to circumvention of regulations. It also grows when real interest rates and yield spreads are low and investors are searching for higher returns, and when there is a large institutional demand for '​safe assets,' for example from insurance companies and pension funds." As the global financial crisis has shown, there are also risks associated with shadow banking due to their reliance on short-​term funding, which can lead to forced asset sales and downward price spirals when investors want their money back at short notice."

Tom Hunt, Director of Treasury Services at AFP published "Money Fund Talk at Crane Data Symposium: New Regs & Alibaba," a recap of last week'​s Crane'​s European Money Fund Symposium in London. He wrote, "Much of the discussion at the Crane Data'​s Money Fund Symposium last week centered around how money market funds (​MMFs) are responding to new and pending regulations. In the United States, many fund companies are building business cases on the feasibility of developing new funds or share classes in response to the new retail MMF definition and operational changes from the regulations. Much of the discussion at the symposium addressed concerns about liquidity and supply, support of the repo market, the Federal Reserve'​s Reverse Repo offering, negative deposit rates in Europe, and responding to clients' inquiries on the various regulation impacts. In Europe, the focus is on the capital buffer proposal by the European Union. The overall sentiment was that it wouldn'​t pass since the Securities and Exchange Commission (​SEC) didn'​t use the mechanism in its final regulations issued in July." His key takeaways were: "​1. Continue to monitor China'​s largest money fund, Yu'​e Bao. Despite over $​90 billion in assets, Yu'​e Bao will continue to grow because it is operated by Alipay.​com, the payment service for Alibaba. The fund is heavily weighted in Chinese bank deposits and is experiencing enormous growth from its inception in June 2013.... 2. Watch for the Financial Accounting Standards Board ruling on floating net asset value (​FNAV) MMFs -- will there be a mismatch to the International Financial Reporting Standards? 3. CME Clearing Collateral. It'​s yet to be determined if FNAV funds will be allowable per IEF2 program. Also discussed were IFRS' accounting treatments for MMFs in Europe. A presenter from PwC expects money funds in Europe to maintain the cash/​cash equivalent classification under IFRS. FASB has yet to rule on regulatory reform in the U.​S. and more information is to follow." In other news, Bloomberg writes "​Money Funds Zero Pain to Worsen as Fed Maneuvers: Credit Markets", which reads, "Money-​market investors who have endured almost-​zero interest rates for about six years are bracing for even worse returns after the Federal Reserve limited how much cash it is willing to sop up. The central bank is working out how best to control short-​term rates after its bond buying policies aimed at suppressing borrowing costs and stimulate economic growth flooded the banking system with $​2.​71 trillion of excess reserves. The Fed, which is forecast to start raising rates next year, surprised market participants earlier this month when it placed a limit on how much cash it will take out of the system each night through its reverse repurchase agreement program. The cap helped push overnight repo rates below what the Fed offers at its reverse repo program last week and sent Treasury bill rates below zero. That'​s adding to the pain of savers who have $​2.​5 trillion parked in money-​market mutual funds, where yields have averaged 0.​05 percent since the end of 2009, according to measures of the biggest 100 taxable funds compiled by Crane Data."

The Financial Times wrote, "Alibaba in Talks for HK Version of Yu'​E Bao Money Market Fund." The piece says, "Alibaba is looking to start a Hong Kong version of its enormously popular Chinese money market fund, which pays higher rates on renminbi deposits than are available on conventional accounts. Its Alipay financial unit is in talks with the Hong Kong Monetary Authority about securing authorisation to offer a local version of its Yu'​E Bao money market fund, which launched in June last year and had already attracted more than Rmb574bn ($​94bn) a year later. The move underscores Alibaba'​s determination to take its template to the world beyond China, now that it has completed its record $​25bn initial public offering in New York. If Alibaba receives approval from both Hong Kong and China, the funds would be invested in the mainland in order to achieve higher returns. The group says it believes it could offer 4 per cent returns, compared with the 1 per cent currently available. "​We are hoping to introduce it by early next year," said Ming Shu, who is responsible for micro finance and SME finance for Alipay, which is also China'​s largest online payments provider.... Currently the main channel through which fund companies can invest offshore renminbi in mainland capital markets is the Renminbi Qualified Foreign Institutional Investor programme. Regulators have not so far approved a money market fund under RQFII, which mainly consists of bond funds and equity exchange traded funds." The FT also published a story on "Fed '​Repo' Tests Drive Scramble for Safety," which reads, "Investors are scrambling for safe assets ahead of the end of the financial quarter, with the scrum for securities exacerbated by the Federal Reserve'​s testing of a key financing tool for an eventual tightening of policy. Yields on short-​term Treasury bills, viewed as ultra-​safe securities, have dipped below zero as the assets attracted heavy buying in the run-​up to the end of the third quarter. Negative yields on the securities mean that money market funds and other big investors are effectively willing to pay the US government for holding their cash over the end of the financial period."

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