However, Larsen says that the EU MMF rules are having an impact on Asian treasurers – including treasurers of US and EU multinationals based in Asia as well as local treasurers using MMFs. “The majority of MMFs sold in the unrestricted markets are EMEA-based MMFs,” he says. “While most asset managers have been communicating to their customers, it is still somewhat foreign for many Asian treasurers to be impacted so directly by non-Asian rules.”
As such, Larsen says the experience has been something of a learning process for treasurers in Asia. “As most EU-based treasurers are living and breathing the rules on a daily basis, it is something of a non-event for them,” he says. “For Asian treasurers, it has taken more time to get comfortable with the new concepts of LVNAV funds and how they still deliver the same risk profile to a treasurer.” Despite the challenges, he notes that so far there has been no across-the-market move of investors from the new LVNAV structure to CNAV government funds as was seen during the US MMF reform.
Shevlin says that while the reforms did create a degree of disruption and required changes in terms of how funds are used and managed, “overall they have been positive – offering investors more choice, liquidity and security.” He also points out the indirect impact of reforms in Europe and the US, which have impacted short-term interest rates markets across the world, “changing the demand and supply for different instruments and maturities”.
Regulatory change in Asia
Could similar reforms be seen in Asia at some point? Shevlin says that while money market funds have been relatively static across the region for many years, “recent regulatory changes in the US and Europe have triggered discussions in some markets about whether local MMF rules are still fit for purpose” – although, as he notes, any changes will take some time to implement.
He also points out that while the types of changes adopted in the US and Europe could theoretically be adopted in Asia, caveats apply. “While the ultimate goals of all MMF regulations are similar – to make funds more liquid, safe and robust – US and EU MMF rules and standards are based on the unique characteristics of their markets,” he says. “Asia-Pacific markets vary in depth, liquidity and the range of investment opportunities available – and these need to be considered before any significant changes can be made.” Shevlin adds that while having safe and liquid funds is a key priority, “ensuring cash is investible and funds can achieve a competitive level of return is also important”.
Larsen agrees that for many restricted markets, such changes would be many years off, “and would take a significant modernisation of the regulatory environment in those countries.” However, he notes that China is an exception: the country, in an effort to liberalise the market and attract offshore investment, “is already on a convergence path”. Hong Kong, likewise, could see greater convergence with EMEA rules in the future. Developments in both markets include the following:
“MMF rules were originally established in 2004 and remained broadly unchanged for several years,” says Shevlin. “But the popularity, rapid growth and current size of RMB MMFs have made them systemically important – and increased regulatory scrutiny.” As such, he says that the China Securities Regulatory Commission (CSRC) has introduced several major changes to MMF regulations in the last few years. These changes “have significantly tightened the rules, de-risking the industry while bringing RMB fund guidelines closer to their western counterparts”.
Larsen says that for Hong Kong there is an expectation that the SFC will issue new rules more in line with EMEA standards. “Several new hires into the regulator are from EMEA-based regulatory bodies and bring with them the knowledge and mindset to standardise the rules towards international standards,” he says. “Hong Kong is also pushing to be a major fund domicile and if they want to market their funds across Asia and into EMEA and the US they will have to adopt similar rules.”
For other unrestricted Asian markets, Larsen says there is less of a push to be a major fund domicile for institutional MMFs – and consequently, less of a focus on specifically aligning local rules with those in Europe. “They will probably be content with allowing EU product to be distributed into their countries by locally licensed entities and sales people, rather than trying to compete as a full-fledged fund domicile location,” he adds. “Effectively this means EU rules may be adopted in-country by default.”
Other market developments
Regulatory reform is not the only factor affecting the direction of travel for money market funds. Shevlin notes that Asia – particularly China – “has been at the forefront of new and innovative MMF distribution methods”, adding that moving to digital platforms has given clients more choice and flexibility. “While these innovations have primarily targeted retail investors, corporate investors can also benefit from some of these improvements,” he says.
Larson notes that MMF portals that previously only operated in the US or EU are now setting up outposts in Asia. “These MMF supermarkets allow clients to invest in multiple funds via one interface, and often automatically integrate with a client’s bank accounts,” he says. “In that same vein, most banks and custody providers are not offering automated sweeps into their own, and third party, money market funds – essentially automating a large piece of a treasurer’s cash management responsibilities.”