Fast forward to 2022, and the landscape has evolved considerably. The conflict in Ukraine has provided another shock to financial markets, with a knock-on impact on the global economy.
“The conflict hasn’t had a direct impact on the types of instruments and high-quality issuers that a well-run money fund invests in,” says Hugo Parry-Wingfield, EMEA Head of Liquidity Investment Specialists at HSBC Asset Management. “But as with any times of disruption, it leads to some adjustments being made.” For example, he says, HSBC Asset Management’s funds are currently running with higher-than-normal levels of liquidity – “which is simply a prudent discipline to follow whenever there’s any market disruption.”
Other notable developments include the prospect of further interest rate hikes, as well as the challenges brought by rising inflation, notes Beccy Milchem, Managing Director – Head of EMEA Cash Management at BlackRock. In addition, she says, few conversations with clients do not touch on the topic of sustainability.
“It’s very topical, given the backdrop around the energy crisis that’s playing out in markets,” Milchem notes. “What we are starting to see is that as investment policies are written, sustainability is front and centre of mind. That goes all the way through from a treasury perspective to cash investing, and what more clients can be doing as short-term investors.”
Return of regulatory reform?
The performance of money market funds during the unprecedented stresses of the pandemic have been identified as evidence that the recent regulatory changes have succeeded in their goals. “In our opinion, the rules that money funds have to follow in Europe and elsewhere have generally worked well,” says Parry-Wingfield.
Nevertheless, regulatory attention is once again on the agenda. “There’s been a particular focus from regulators on both sides of the Atlantic to look at how money funds managed the crisis,” Parry-Wingfield notes. “They’ve been considering whether there are any perceived weaknesses or areas where those rules could be further enhanced to improve the resilience of money funds.”
One particular focus is on the value of liquidity fees and redemption gates, which arguably incentivise investors to redeem pre-emptively during times of market stress, in order to avoid being subject to those fees and gates.
In the US, the SEC voted in December 2021 to propose a new round of changes, with the goal of improving the resilience and transparency of MMFs, and reducing the likelihood of future runs on MMFs during periods of stress. The proposed changes include higher liquidity requirements, as well as the removal of liquidity fees and gates. Instead, funds would be required to implement swing pricing arrangements, under which redeeming investors would bear the liquidity costs of redemptions.
In Europe, meanwhile, the EC is already scheduled to review the adequacy of the structures introduced in the 2017 regulation by July 2022. In February, the European Securities and Markets Authority (ESMA) issued a report outlining its opinion on proposed reforms to the regulatory framework for EU MMFs. The proposed measures include decoupling regulatory thresholds from suspensions, gates and redemption fees, as well as other actions such as removing the possibility of using amortised costs for LVNAV MMFs.
Impact of future changes
The question is to what extent further regulatory changes will affect the appeal of money market funds for investors. Przybylski recalls the significant impact of the 2016 US reforms: “As a result of that action, US$1.1trn equivalent of prime assets shifted into government money market funds. The prime space has definitely shrunk – the overall industry is now about US$600bn, from a number that was close to US$1.3trn in the past. So the challenge is regulation that by design limits choice for investors.”
In Europe, likewise, industry players are looking closely at the impact of future changes on investors. “The ESMA proposal calls for the ability to round to one to be removed, which would effectively eliminate the LVNAV money market fund – instead, you would end up with a third variable NAV structure,” explains BlackRock’s Milchem.
She adds that it is only three years since investors spent a considerable amount of time and resources building policies, controls and oversight of the new product structures that were created under the 2017 policy framework. “So we think that corporate treasurers will share our position that a policy response eliminating this structure is not really appropriate, absent some clear evidence that the structure itself resulted in this vulnerability in March 2020 – which we think is hard to evidence.”
While the proposed changes could have significant repercussions if they come to pass, however, this could take some time to materialise. “In terms of where we are at this stage in Europe, it’s important for investors to be clear that no rule changes have yet been determined,” says Parry-Wingfield. “Secondly, it’s still not known when that would be, or what any implementation period would be.” He points out that during the previous reform, this was a process that took many years to complete. “So I think it’s very important for investors to keep up-to-date with what’s going on – but this isn’t something that’s about to happen in the next few months.”
In the meantime, says Parry-Wingfield, it is important that investors take part in the conversation so that their voices are heard – for example, by responding to the European Commission’s public consultation, which is open until 13th May.
Milchem, likewise, notes “there is still time to help shape that landscape, and the value placed on the utility of money market funds needs to be conveyed to policy makers. One aim that we at BlackRock have – and I know that the Institutional Money Market Funds Association (IMMFA) has as well – is around bringing investor voices to the table to help influence the debate.”