M-Mkt Fund Vulnerabilities - YELLEN, 3/30/23

yogibearbull

"The structural vulnerabilities at the heart of money market and open-end funds aren’t new. In the banking sector, capital and liquidity requirements and federal deposit insurance reduce the likelihood of runs taking place. In case runs occur, access to the discount window helps provide buffers for banks. Yet the financial stability risks posed by money market and open-end funds have not been sufficiently addressed.

Over the past two years, the SEC has proposed rules to mitigate the vulnerabilities plaguing these funds.13 The SEC’s proposals would reduce the first-mover advantage, reducing run incentives during times of stress. They would also require new liquidity management tools, while mandating more comprehensive and timely information on these funds for the SEC and investors."

https://home.treasury.gov/news/press-releases/jy1376

msf

If there is any place where the vulnerabilities of the system to runs and fire sales have been clear-cut, it is money market funds.
...
Even without a fixed NAV, liquidity mismatch in other kinds of funds can still make them vulnerable to runs and fire sales.

Falling between the cracks here are floating NAV money market funds - neither fixed NAV nor other (non-MM) kind of fund. I suspect this was an unintended omission.

The alternative would be that she considers floating NAV MMFs to be relatively immune to runs and fire sales. That's not beyond the realm of possibility. The MMF runs she describes are due to funds breaking a buck and investors rushing for the gates (a la SVB, Reserve Fund) - first mover advantage.

Floating NAV MMFs by definition can't break a buck - they aren't fixed to a $1 nominal NAV. Redemption values vary continuously (fractions of a percent) rather than discretely (1%, a penny at a time).

FWIW, one can invest in floating NAV MMFs via Merrill. That's one of the very few advantages I can see in that brokerage, though one of which I'm not partaking.

Footnote 13 (in the OP) is a cite to https://www.sec.gov/news/press-release/2021-258

The proposed MMF rules she refers to would have removed redemption fees/gating, and imposed swing pricing on institutional funds. This 2021 proposal is still being worked on and seems to still be accepting comments (last one was Feb 2023).

Proposal: https://www.sec.gov/rules/proposed/2021/34-93784.pdf
Fact sheet: https://www.sec.gov/rules/proposed/2021/ic-34441-fact-sheet.pdf
Comments: https://www.sec.gov/comments/s7-22-21/s72221.htm

Mutual fund managers responded to the redemption fee/gating rules by managing the funds more conservatively so that the rules would never be triggered. They were concerned that if a fund got close to that point, investors would stampede out - first mover advantage redux.

Or something else might spook investors. Say, a pandemic.

Evidence indicates that SEC's reforms did not prevent runs during the COVID-19 pandemic. For example, prime MMFs—which can invest in all types of short-term debt instruments—held by institutional investors experienced net redemptions of about 30 percent of their total assets in a 2-week period in March 2020 (see figure). Some evidence also indicates SEC's reforms may have contributed to the runs. Some investors may have preemptively redeemed MMF shares to avoid incurring a liquidity fee or losing access to their funds under a redemption gate.

https://www.gao.gov/products/gao-23-105535

Notable in that report and in the SEC's proposal is the focus on institutional investors. (Swing pricing for institutional investors, relaxed restrictions on retail investors.) As with SVB, institutional investors are apparently the elephants in the room stomping on everyone else.