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Thread: SEC to require an exit fee from money markets.

  1. #1

    SEC to require an exit fee from money markets.

    The SEC is going to start charging an exit fee on certain types of money markets to keep people from panic selling. As far as I can tell it's retroactive which would be a serious violation of contract law (not that anyone cares about rule of law anymore).

    Also they are going to add something called a floating NAV. I'm not sure what that is but I know investors don't like it. And guess what, US Treasuries are exempt from this "floating NAV" to try and entice more people to invest in treasuries.

    http://www.chicagotribune.com/busine...,3985197.story

    So if the US is in such supposedly rock solid financial footing, why would they need a mechanism to prevent people from selling dollars?



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  3. #2
    Quote Originally Posted by Madison320 View Post
    The SEC is going to start charging an exit fee on certain types of money markets to keep people from panic selling. As far as I can tell it's retroactive which would be a serious violation of contract law (not that anyone cares about rule of law anymore).

    Also they are going to add something called a floating NAV. I'm not sure what that is but I know investors don't like it. And guess what, US Treasuries are exempt from this "floating NAV" to try and entice more people to invest in treasuries.

    http://www.chicagotribune.com/busine...,3985197.story

    So if the US is in such supposedly rock solid financial footing, why would they need a mechanism to prevent people from selling dollars?
    Money market shares have always maintained a value of $1/share, making them the same as a savings account in terms of value. But that has always had some risk, and that risk came to pass during the 2008 meltdown. Busted the buck.

    The main pillar of the rule requires "prime" money funds used by institutional investors to float their values, instead of letting them maintain a stable value at $1 per share. The goal is to prevent investors from getting spooked by the prospect of funds breaking the buck, or their net asset value falling below $1 per share.

    In addition, fund boards will have discretion to lower "gates" on redemptions, or charge fees of up to 2 percent if market stress causes a fund's weekly liquid assets to fall below 30 percent.

    Both measures are slated to take effect in two years.

    The final adoption of the reforms was the culmination of years of fierce debate, dating back to the financial crisis.

    In 2008, the Reserve Primary Fund's exposure to Lehman Brothers prompted panicked investors to withdraw their money in a run that led the fund to "break the buck."

    That in turn forced the Federal Reserve temporarily to backstop the $2.6 trillion industry until the chaos subsided.
    ...
    http://www.chicagotribune.com/busine...578,full.story
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  4. #3
    Quote Originally Posted by Brian4Liberty View Post
    The final adoption of the reforms was the culmination of years of fierce debate, dating back to the financial crisis. In 2008, the Reserve Primary Fund's exposure to Lehman Brothers prompted panicked investors to withdraw their money in a run that led the fund to "break the buck."
    I confused about this. I thought the crash was in stocks and not the dollar. The dollar actually strengthened during the crash. Why are they trying to stop a run on the dollar? Why aren't they trying to stop a run on stocks since stocks are what crashed? Not that I'm in favor of that but I think it shows they are worried about a dollar crash more than they lead on.

  5. #4
    Quote Originally Posted by Madison320 View Post
    I confused about this. I thought the crash was in stocks and not the dollar. The dollar actually strengthened during the crash. Why are they trying to stop a run on the dollar? Why aren't they trying to stop a run on stocks since stocks are what crashed? Not that I'm in favor of that but I think it shows they are worried about a dollar crash more than they lead on.
    Money market funds are supposed to consist of nothing but the highest quality, short term instruments. It turned out that some of the low quality (fraudulently called high-quality) mortgage derivatives ended up in money markets. They were not liquid (and may have had no value), and people tried to cash out. NAV fell below $1/share.
    "Foreign aid is taking money from the poor people of a rich country, and giving it to the rich people of a poor country." - Ron Paul
    "Beware the Military-Industrial-Financial-Pharma-Corporate-Internet-Media-Government Complex." - B4L update of General Dwight D. Eisenhower
    "Debt is the drug, Wall St. Banksters are the dealers, and politicians are the addicts." - B4L
    "Totally free immigration? I've never taken that position. I believe in national sovereignty." - Ron Paul

    Proponent of real science.
    The views and opinions expressed here are solely my own, and do not represent this forum or any other entities or persons.

  6. #5
    LibForestPaul
    Member

    Quote Originally Posted by Brian4Liberty View Post
    Money market funds are supposed to consist of nothing but the highest quality, short term instruments. It turned out that some of the low quality (fraudulently called high-quality) mortgage derivatives ended up in money markets. They were not liquid (and may have had no value), and people tried to cash out. NAV fell below $1/share.
    Did Corzine from MF Global infamy hatch this plan? I don't know, but it seems like where this is heading.
    Schlep:Hey give me my sandwich back.
    IB: Wait, just a few more bites.
    Schlep: No...
    IB: Here you go, have a tomato.
    Schlep: Where's my pastrami?
    IB: Too late, all gone.

  7. #6
    Quote Originally Posted by Madison320 View Post
    The SEC is going to start charging an exit fee on certain types of money markets to keep people from panic selling.
    Actually, they are just going to permit funds to charge it, as a way of staving off runs.

    Also they are going to add something called a floating NAV. I'm not sure what that is but I know investors don't like it. And guess what, US Treasuries are exempt from this "floating NAV" to try and entice more people to invest in treasuries.
    This statement you've made is indeed very confused, but I'm not sure where to start to try to correct it. Jordan, eric_cartman, want to help me out here?

    Quote Originally Posted by Madison320 View Post
    I confused about this. Why are they trying to stop a run on the dollar?
    It is to stave off runs in money market funds, specifically, not in the dollar itself.

    You see, money market funds are kind of... how can I put this... similar to fractional reserve in a way. Now they have all the reserves, 100% reserves (at least they'd better!). However, the time structure of their assets and their liabilities are mismatched. Their liabilities are all instantaneous. You can withdraw your money at any moment, and they promise to give you it. However, their assets are not instantaneously liquidatable. They have terms. Maybe they've bought somebody's 5-year municipal bonds. They can't get at that money for 5 years -- the municipality has it.

    Does that make sense?

    So the average term for the assets might be 50 days or something. While you can see that the average term for the liabilities is zero, if everyone could in theory withdraw their funds at any moment. If everyone does withdraw at once, or even if just too many people withdraw at once, then it will be the same situation as at the bank run. The money's just not there. Even this could usually be solved, but if all the other money market funds are experiencing similar problems, then none of them will buy your assets from you and give you some liquidity. And so then you're stuck.

    Yes, it all can be confusing. So here's the bottom line to take away:

    This is just one more excellent reason to keep your cash in treasury bills that you own directly or in treasury-only money market funds.

  8. #7
    Quote Originally Posted by helmuth_hubener View Post
    Actually, they are just going to permit funds to charge it, as a way of staving off runs.

    This statement you've made is indeed very confused, but I'm not sure where to start to try to correct it. Jordan, eric_cartman, want to help me out here?

    It is to stave off runs in money market funds, specifically, not in the dollar itself.

    You see, money market funds are kind of... how can I put this... similar to fractional reserve in a way. Now they have all the reserves, 100% reserves (at least they'd better!). However, the time structure of their assets and their liabilities are mismatched. Their liabilities are all instantaneous. You can withdraw your money at any moment, and they promise to give you it. However, their assets are not instantaneously liquidatable. They have terms. Maybe they've bought somebody's 5-year municipal bonds. They can't get at that money for 5 years -- the municipality has it.

    Does that make sense?

    So the average term for the assets might be 50 days or something. While you can see that the average term for the liabilities is zero, if everyone could in theory withdraw their funds at any moment. If everyone does withdraw at once, or even if just too many people withdraw at once, then it will be the same situation as at the bank run. The money's just not there. Even this could usually be solved, but if all the other money market funds are experiencing similar problems, then none of them will buy your assets from you and give you some liquidity. And so then you're stuck.

    Yes, it all can be confusing. So here's the bottom line to take away:

    This is just one more excellent reason to keep your cash in treasury bills that you own directly or in treasury-only money market funds.
    Good description. I would add that even if there is 5 year muni bond in the MM portfolio, that should be liquid, and could be sold to meet liabilities. But in the case of the mortgage backed derivatives, their value went to nearly zero, thus impossible (or pointless) to sell.
    "Foreign aid is taking money from the poor people of a rich country, and giving it to the rich people of a poor country." - Ron Paul
    "Beware the Military-Industrial-Financial-Pharma-Corporate-Internet-Media-Government Complex." - B4L update of General Dwight D. Eisenhower
    "Debt is the drug, Wall St. Banksters are the dealers, and politicians are the addicts." - B4L
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  9. #8
    Quote Originally Posted by Brian4Liberty View Post
    Good description. I would add that even if there is 5 year muni bond in the MM portfolio, that should be liquid, and could be sold to meet liabilities. But in the case of the mortgage backed derivatives, their value went to nearly zero, thus impossible (or pointless) to sell.
    Sold to whom, though? That's the rub. Mortgage-backed derivatives could always be sold, too. Until they couldn't.

    So everything is no problem. Until it is.

    Cash is for safety. Keep your cash safe. Don't chase yield with your cash. Treasuries or pure treasury funds. That's my take.



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  11. #9
    Quote Originally Posted by helmuth_hubener View Post
    Sold to whom, though? That's the rub. Mortgage-backed derivatives could always be sold, too. Until they couldn't.

    So everything is no problem. Until it is.

    Cash is for safety. Keep your cash safe. Don't chase yield with your cash. Treasuries or pure treasury funds. That's my take.
    Of course. But even your cash or US treasuries could become worthless. Actual they do become worth less each day.

    Your hypothetical Muni does have the potential for default. It's happened before. Standard money market accounts wouldn't have those though, unless someone is up to shenanigans. Specialized money market funds might invest in municipal bonds.
    "Foreign aid is taking money from the poor people of a rich country, and giving it to the rich people of a poor country." - Ron Paul
    "Beware the Military-Industrial-Financial-Pharma-Corporate-Internet-Media-Government Complex." - B4L update of General Dwight D. Eisenhower
    "Debt is the drug, Wall St. Banksters are the dealers, and politicians are the addicts." - B4L
    "Totally free immigration? I've never taken that position. I believe in national sovereignty." - Ron Paul

    Proponent of real science.
    The views and opinions expressed here are solely my own, and do not represent this forum or any other entities or persons.

  12. #10
    New York Fed report on Money Market Funds that could have broken the buck. Money Market Accounts are more conservative than Funds.

    This would have been used to some extent in drafting the new law, err, regulation.

    Twenty-Eight Money Market Funds That Could Have Broken the Buck: New Data on Losses during the 2008 Crisis
    Marco Cipriani, Michael Holscher, Antoine Martin, and Patrick McCabe

    During the financial crisis in 2008, just one money market fund (MMF) “broke the buck”—that is, its share price dropped below one dollar. The Reserve Primary Fund announced on September 16 that the value of its shares had dropped to 97 cents. As we discussed in a previous post, Reserve’s announcement helped spark a widespread, damaging run on MMFs that slowed only when the federal government intervened three days later to backstop the funds.

    But new data that we first published in a New York Fed staff report and discussed in a Brookings paper show that at least twenty-nine MMFs had losses large enough to cause them to break the buck in September and October 2008 despite significant government intervention and support of the sector. Five funds or more experienced losses exceeding the 3 percent reported by Reserve, and one fund reported a loss of nearly 10 percent. Among the twenty-nine funds that would have broken the buck without sponsor support, the average loss was 2.2 percent.

    Yet, the losses for twenty-eight of these MMFs may have gone unnoticed during the crisis, as neither their shareholders nor almost anyone else could have observed their magnitudes at the time. As in other episodes in which MMFs suffered significant losses, the losses were absorbed—and hence obscured—by voluntary financial support from MMF sponsors (the MMFs’ asset management firms or their parent companies). The extensive record of sponsor support for MMFs does allow us to look back to the 2008 crisis and other periods of strain for indirect evidence about funds’ losses. In a 2010 report, Moody’s found 144 cases in which U.S. MMFs received support from sponsors between 1989 and 2003. Brady, Anadu, and Cooper (2012) documented 123 instances of support for seventy-eight different MMFs between 2007 and 2011, including thirty-one cases in which support was large enough that it probably was needed to prevent funds from breaking the buck. Still, these data only allow estimates of what MMF losses must have been to motivate sponsors’ actions.

    In contrast, the data we describe are market-based values of MMF portfolios reported confidentially by the funds themselves during the crisis to the Department of the Treasury (“Treasury”) and the Securities and Exchange Commission (SEC). In general, these “shadow” net asset values (NAVs) are invisible to investors and the public, as MMFs are permitted to round their reported share values to $1 so long as the shadow NAV remains above $0.995. Only if the shadow NAV drops below that threshold does the fund break the buck—unless it receives sponsor support. During the crisis, many MMFs did receive such support, so their shadow NAVs remained invisible. However, any MMF with a shadow NAV below $0.9975 that participated in Treasury’s Temporary Guarantee Program for MMFs was required to report to Treasury and the SEC what its shadow NAV would have been without some forms of sponsor support, such as capital support agreements. Since virtually the entire industry participated in the program, these data provide an unprecedented record of MMFs’ portfolio losses at the time.

    Even so, the NAV data do not reflect the full extent of losses that might have occurred without sponsor interventions. Some of the reported shadow NAVs were likely boosted by common forms of sponsor support, such as direct cash infusions and sales of securities to sponsors at above-market prices. Of course, the data also do not reflect portfolio losses that might have occurred in the absence of Treasury’s guarantee program and other government support for MMFs in 2008.

    In the table below, line 1 shows that seventy-two MMFs reported shadow NAVs at least once from September 5 to October 17, 2008, indicating that their shadow NAVs dipped below $0.9975 at some point in this period. Although some funds reported data daily, all funds with shadow NAVs below $0.9975 were required to report at least weekly, and the number of reports jumped each Friday. Line 1 lists the number of funds reporting shadow NAVs on each Friday, which ranged from nineteen to sixty-three. Line 2 shows that on most Fridays the majority of reporting MMFs had shadow NAVs of $0.9975 or less.

    Twenty-nine MMFs reported a shadow NAV below $0.995—low enough to break the buck, absent sponsor support—at some point during this episode (line 3). As many as eleven MMFs on any particular Friday reported shadow NAVs below 99.5 cents, including five funds that reported NAVs below this level before the Lehman Brothers bankruptcy. Average shadow NAVs for all reporting funds, excluding the effects of guarantees, dropped to $0.993 on October 3 and October 17 (line 4). Among funds with NAVs falling below $0.995 at some point, minimum shadow NAVs averaged $0.978 (line 5, column 1). That is, these funds lost, on average, at least 2.2 percent during the crisis.

    These new data on shadow NAVs represent a significant contribution to our understanding of MMF risks and the 2008 crisis. By lifting the veil of sponsor support, the data reveal how large and extensive MMF losses actually were. Indeed, one fund reported an NAV of $0.903, almost 10 percent below its “stable” $1 NAV! This information is useful for designing reforms to mitigate the risks that MMFs pose to financial stability. For example, the magnitudes of potential losses are important for calibrating the size of a capital buffer or minimum balance at risk to protect MMFs from runs.

    The scale and scope of the losses in 2008 also highlight the significance of sponsor support for MMFs. After all, what made the Reserve Primary Fund unique in 2008 was neither its exposure to Lehman Brothers nor its portfolio losses, but the fact that its sponsor could not absorb its losses. However, the industry’s reliance on implicit recourse to sponsors is systemically risky because it creates channels for transmitting destabilizing strains between sponsors and their “off-balance-sheet” MMFs, and because uncertainty about whether sponsors will come to funds’ rescue may precipitate runs (McCabe 2010). Hence, the data we have described underscore the need for robust and effective MMF reforms that would provide a form of stability to the MMF industry not predicated on voluntary and uncertain support from sponsors.
    ...
    More:
    http://libertystreeteconomics.newyor...he-2008-c.html
    "Foreign aid is taking money from the poor people of a rich country, and giving it to the rich people of a poor country." - Ron Paul
    "Beware the Military-Industrial-Financial-Pharma-Corporate-Internet-Media-Government Complex." - B4L update of General Dwight D. Eisenhower
    "Debt is the drug, Wall St. Banksters are the dealers, and politicians are the addicts." - B4L
    "Totally free immigration? I've never taken that position. I believe in national sovereignty." - Ron Paul

    Proponent of real science.
    The views and opinions expressed here are solely my own, and do not represent this forum or any other entities or persons.

  13. #11
    So as it was claimed. I think it had more to do with pure fright more than anything. Since the funds were in less than 270 day stuff they still had to have those funds to cover the short term things it was in.

    You gotta remember 2008 was such an irrational time.

    Quote Originally Posted by Brian4Liberty View Post
    Money market funds are supposed to consist of nothing but the highest quality, short term instruments. It turned out that some of the low quality (fraudulently called high-quality) mortgage derivatives ended up in money markets. They were not liquid (and may have had no value), and people tried to cash out. NAV fell below $1/share.

  14. #12
    Quote Originally Posted by Brian4Liberty View Post
    Standard money market accounts .... Specialized money market funds
    Quote Originally Posted by Brian4Liberty View Post
    New York Fed report on Money Market Funds .... Money Market Accounts are more conservative than Funds.
    I don't know what you are talking about. A money market account would be an individual account that one has with a money market fund. Much like a bank account or a something else account. You seem to be using this term in some special and, to me, un-heard-of way that is something to the effect of a special money market fund with extra-conservative rules. You may be talking about something real, but the terminology you are using I have never heard, so that's confusing me. I mean, a money market fund is a money market fund. There are different types and qualities, yes.

  15. #13
    Quote Originally Posted by helmuth_hubener View Post
    Actually, they are just going to permit funds to charge it, as a way of staving off runs.
    I think you're right but is that much better? Suppose they did the same thing with normal bank accounts. The govt tells banks they can charge customers 10% for taking their money out. Is that any better than the govt charging 10%? Either way you're out 10%. It seems to me the only difference is whether the thief is the govt or the bank. It sounds to me like the govt is allowing the bank to steal.

  16. #14
    Quote Originally Posted by helmuth_hubener View Post
    I don't know what you are talking about. A money market account would be an individual account that one has with a money market fund. Much like a bank account or a something else account. You seem to be using this term in some special and, to me, un-heard-of way that is something to the effect of a special money market fund with extra-conservative rules. You may be talking about something real, but the terminology you are using I have never heard, so that's confusing me. I mean, a money market fund is a money market fund. There are different types and qualities, yes.
    I have seen (and invested in) muni money market funds. They are not called money market "accounts" though.

    A quick google search gives this link:

    Money Market Funds vs Money Market Accounts

    Money market accounts are bank alternatives to money market mutual funds. What’s the difference? The main factors are risk and choices. Let’s do a comparison of money market funds vs. money market accounts so you can make the best choice.
    Money Market Accounts

    Money market accounts are your plain-vanilla option. They’re what you’ll find at a bank. Money market accounts should pay you a nice annual percentage yield (APY) while keeping your money safe.
    Money Market Funds

    Money market funds are more complex – you’ll find more options and you’ll likely earn a slightly higher yield than you’d get from a money market account. Some examples of money market fund options are:
    US Treasury backed money market funds
    US government and agency backed money market funds
    Municipal money market funds
    Local municipal money market funds
    Socially responsible money market funds
    The options listed above allow an investor to choose the money market instruments used in the fund. Some people are only comfortable with securities backed by the US government. Likewise, some people use municipal money market funds in order to earn tax-free income.

    Safety First

    For some investors, safety is more important than high returns. If you agree, you should stick with money market accounts. Money market accounts offered by banks are typically FDIC insured (although you should check with your bank and the FDIC for details).
    If money market accounts are FDIC insured, it’s only fair that they would offer a slightly lower rate than a money market fund.

    Money Market Account or Money Market Fund?

    Which should you use? It depends on what you want. Money market accounts have their place, as do funds.
    The main thing is to consider your needs. If you don’t need the options available from funds, just use a money market account. You should get a competitive return from a money market account, and you can sleep at night knowing that you’re taking less risk.

    In addition, you should consider how much time and energy you’re willing to invest. Money market accounts will be easier to find at standard banks. For a money market fund, you may have to open an account with a brokerage firm or mutual fund company.
    ...
    More:
    http://banking.about.com/od/investments/a/mmavsmmf.htm
    "Foreign aid is taking money from the poor people of a rich country, and giving it to the rich people of a poor country." - Ron Paul
    "Beware the Military-Industrial-Financial-Pharma-Corporate-Internet-Media-Government Complex." - B4L update of General Dwight D. Eisenhower
    "Debt is the drug, Wall St. Banksters are the dealers, and politicians are the addicts." - B4L
    "Totally free immigration? I've never taken that position. I believe in national sovereignty." - Ron Paul

    Proponent of real science.
    The views and opinions expressed here are solely my own, and do not represent this forum or any other entities or persons.

  17. #15
    Quote Originally Posted by Madison320 View Post
    I think you're right but is that much better? Suppose they did the same thing with normal bank accounts. The govt tells banks they can charge customers 10% for taking their money out. Is that any better than the govt charging 10%? Either way you're out 10%. It seems to me the only difference is whether the thief is the govt or the bank. It sounds to me like the govt is allowing the bank to steal.
    Losing 10% of your money to withdraw it when you desperately need it (actually, I believe the maximum fee is 2% under this new rule, but I understand your point) would indeed be a big bummer. That is why, in my opinion, the practical take-away from this news is this:

    This is just one more excellent reason to keep your cash in treasury bills that you own directly or in treasury-only money market funds.

    Also, consider this: why would you need to suddenly withdraw your cash during a financial crisis situation such as would cause widespread anxiety about money market funds? Couldn't you just wait it out? Fee or no fee, that would certainly be the better situation to find yourself in.

    Also, fee or no fee, what is important is the make-up and management of the fund itself. Would you rather lose 2% to an exit fee, or up to 100% to default, poor management, or fraud? Me, I don't want to lose any. So that is why pure Treasuries are the best. US Treasury bills have, effectively, no default risk.

    In short, this new allowance of exit fees to be charged by money market funds does not seem to me to affect any financial decisions that one should make. One should still keep one's cash in the safest way possible: US Treasury bills. That advice stays the same. This new permission for exit fees is an attempt to make other, non-US Treasury, money market funds safer, and it may actually succeed in doing that, to an extent. But they will never be as safe as pure Treasuries.

    This is still good information and I thank you for posting it. My conclusion after examining it is simply that the change should make no difference to the wise investor.

  18. #16
    The exit fee is probably much less than government confiscation.



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  20. #17
    Quote Originally Posted by helmuth_hubener View Post
    This is still good information and I thank you for posting it. My conclusion after examining it is simply that the change should make no difference to the wise investor.
    I'm not in cash anyways. What bothers me is the trend.

  21. #18
    Quote Originally Posted by Brian4Liberty View Post
    I have seen (and invested in) muni money market funds. They are not called money market "accounts" though.
    Ahh, you're talking about a money market deposit account at a bank or credit union.

    I would not recommend such a thing for the money that's precious to you. It has counter-party risk. It is less safe than an actual money market fund. These money market deposit accounts have all the problems of any other bank savings account. They essentially are a savings account, just with a special name. You likely cannot look up your bank's money market account financials (if you find a bank where you can do this, let me know). You can't look up the make-up of its investments. You know why? Because it's not segregated. It's just in a big pool with all the bank's other assets. With an actual money market fund, you can look up exactly what you are putting your money into: See this, for example. You can see they're pretty much all in Treasuries (99.26%), and the longest maturity is a note coming due Jun 30, 2015. Looks good to me. This would be a good, safe place to store your cash.

    How about, in contrast, a money market deposit account at Bank of America. Where is your money going if you deposit it in there? Down a black hole. If you can find the answer, let me know. But you won't. Basically, it just becomes a part of BoA's general slush fund and will go into whatever BoA jolly well feels it should go into, and you don't get any say about it; you don't even get to know about it. It's just a savings account with a slightly higher rate or return in exchange for making only 6 transfers/withdrawals per year. Now I'm not saying it's a super-dangerous place for your cash. It's just not as safe as holding US Treasuries.

  22. #19
    Quote Originally Posted by Madison320 View Post
    I'm not in cash anyways. What bothers me is the trend.
    Are you saying you have absolutely no cash reserves? No "emergency fund"?

  23. #20
    OK, having looked into this further, to make sure that it has no implications for retail-level investors, I have discovered that, in fact, it does!

    The Chicago Tribune and other MSM sources were -- I know you'll be shocked! -- less than perfectly clear and accurate about exactly what this rule is and what it means. Here is the rule change put in simple, clear terms, courtest of MorningStar:

    Required Liquidity Fees
    If a money-fund's holding can be easily and readily converted to true cash, the SEC designates that holding as being either a "daily liquid" or "weekly liquid" asset. Should a fund run low on these liquid securities, such that its weekly liquid assets are calculated to be less than 10% of its total assets, then under the new rules the fund must impose a liquidity fee of 1% on redemption requests.
    Effectively, those redeeming will receive 99 cents on the dollar, with the remaining penny remaining in the fund as a payment to existing shareholders. A fund may escape this provision only if its board of directors, including a majority of independent directors, overrides the automatic imposition of the fee.

    Optional Liquidity Fees
    If a fund's weekly liquid assets are calculated to be less than 30% of its total assets, then that fund may impose an optional liquidity fee. The optional fee, for reasons that remain unclear, would be 2%--double that of the required liquidity fee when the fund breaches the 10% liquidity threshold. Once again, this fee must be supported by the fund's board of directors, including a majority of its independent directors.

    Optional Redemption Gates
    With funds that have less than 30% in weekly liquid assets, fund boards (including, you guessed it, the majority of independent directors) may also vote for the stronger measure of shutting down redemptions altogether. Such gates, as they are called, can be imposed for no more than 10 days within a given 90-day period. When activated, though, they have the effect of completely cutting off all transfers, so that shareholders wishing to access their money funds for any reason are shut down until the gate is lifted.

    -- http://news.morningstar.com/articlen...aspx?id=657610

    Here is the kicker: "Several reports seem to suggest, as does the SEC's press release, that the rules apply only to institutional funds. Not so--the most notable modification, requiring some money funds to float their net asset values rather than fix the price at a constant $1.00, is indeed for institutional funds only. But provisions for liquidity fees and redemption gates apply to all funds, both institutional and retail."

    So, if you have your money in a money market fund account, the fund can now legally declare a "money market holiday" and refuse to give anyone their money for up to 10 days.

    That sounds really bad for liquidity. You can just imagine that there's a crisis, and you want your money, and now you can't get it. Horrible! But here's the thing: the rules don't actually change the fundamentals. Even back in the good old days (five days ago), if the money wasn't there, then the money wasn't there. The money market fund can't give you money that it doesn't have, rule or no rule. Well, actually, they can -- in the 2008 crisis, many companies running money market funds paid for money market redemptions out of their own pockets, to avoid the stigma and bad reputation that would come with not doing so. But one way or another, the money has to come from somewhere.

    So how can one avoid being a victim of a run on the MMF bank? Simple: only invest in funds that invest solely in highly liquid, very high-quality, short-term instruments. For me, that means US Treasuries only. Those are the safest, because they have essentially no credit risk, and no default risk. Why? The issuer controls the currency they are denominated in. The issuer, the federal government, can always tax more to cover the Treasury obligations, and they can always borrow more, but not only that, if it comes down to it, they can also always just create more dollars and use that to pay off their obligations.

    The money market funds can avoid the new rules entirely by having a sufficient amount of "daily liquid assets" and "weekly liquid assets." What are those?

    Daily Liquid Assets means:
    (i) Cash;
    (ii) Direct obligations of the U.S. Government; or
    (iii) Securities that will mature or are subject to a Demand Feature that is exercisable and payable within one Business Day.

    (32) Weekly Liquid Assets means:
    (i) Cash;
    (ii) Direct obligations of the U.S. Government;
    (iii) Government Securities that are issued by a person controlled or supervised by and acting as an instrumentality of the Government of the United States pursuant to authority granted by the Congress of the United States that:
    (A) Are issued at a discount to the principal amount to be repaid at maturity; and
    (B) Have a remaining maturity date of 60 days or less; or
    (iv) Securities that will mature or are subject to a Demand Feature that is exercisable and payable within five Business Days.

    -- http://www.sec.gov/rules/final/2010/...amendments.pdf

    So, a high-quality 100% Treasury fund, like SHV which I linked to above and would recommend, is unaffected. 10%? 30%? Ha! 100% of their assets are in so-called "Daily Liquid Assets."

  24. #21
    Quote Originally Posted by Madison320 View Post
    I'm not in cash anyways. What bothers me is the trend.
    So do you really have no cash reserves, Madison? No emergency fund?

  25. #22
    So, really, no cash, Madison320?



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