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                                                                                         Updated March 24, 2020

Money Market Mutual Funds: A Financial Stability Case Study


A money market mutual fund (MMF) is a mutual fund that
under Securities and Exchange Commission (SEC) Rule 2a-
7 can invest only in high-quality, short-term debt securities,
such as U.S. Treasury bills or commercial paper (a type of
corporate debt). MMFs are commonly considered as safe
alternatives to bank deposits, although they are not
federally insured like bank deposits. However, this
perceived-to-be-safe financial instrument triggered major
market disruptions in 2008 that accelerated the 2007-2009
financial crisis. At the time, the Treasury Department and
the Fed developed multiple intervention tools. As the 2020
coronavirus-induced market stress continues, some of the
same tools are being reconsidered. The Fed reintroduced its
MMF facility. The Coronavirus Aid, Relief, and Economic
Security Act of 2020 (S. 3548) also proposes to permit a
Treasury Department guarantee program for temporary use
during the coronavirus (COVID-19) outbreak.


On September 15, 2008, Lehman Brothers Holdings Inc., an
investment bank, filed for bankruptcy. The next day, one
prominent MMF    the Reserve Primary Fund  saw its per
share price fall from $1.00 to $0.97 after writing off its
Lehman debt. This event triggered an array of market
reactions, including investors' redemptions of more than
$250 billion throughout the MMF industry within a few
days of the bankruptcy. The consequences of these actions
were potentially so dire to U.S. financial stability that the
government ultimately intervened:

* The Treasury Department provided explicit temporary
   deposit insurance to all MMF investors. Over its life, the
   program guaranteed more than $3 trillion in deposits
   and earned $1.2 billion in insurance coverage fees, but
   no guaranteed funds failed. Treasury announced this
   program without seeking specific congressional
   authorization, justifying the program on the grounds that
   guaranteeing MMFs would protect the value of the
   dollar. After the fact, Congress addressed the guarantee
   in the Emergency Economic Stabilization Act (P.L. 110-
   343), reimbursing the exchange stability fund (ESF) that
   backed the guarantee, but also forbidding the future use
   of the ESF to provide such a guarantee.

* The Federal Reserve System also established multiple
   emergency liquidity facilities under its statutory
   authority invoked by unusual and exigent
   circumstances in September and October of 2008 to
   provide a backstop to MMFs and commercial paper as
   part of a broader crisis response. These programs
   expired without loss between late 2009 and early 2010.


Threats to financial stability, or systemic risk, can be
viewed in different ways (e.g., spillover, contagion, and
negative feedback loops). They largely relate to the
transmission of risks from one event to broadly affect the
confidence and functioning of the financial system as a
whole. MMFs pose financial stability concerns because
they demonstrated during the 2008 market events that they
were susceptible to sudden large redemptions (runs),
causing dislocation in short-term funding markets. Share
redemption is the MMF feature that is often discussed
under the context of runs.

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Share redemption allows MMF investors to exit their
investment positions by selling their shares back to the fund
on demand. Investors redeem MMF shares at per share net
asset value (NAV), meaning the value of a fund's assets
minus liabilities. Prior to the 2007-2009 crisis, MMFs
generally maintained a stable NAV at $1.00 per share,
paying dividends as their value rises, thus closely
mimicking the features of a bank deposit. If its stable NAV
drops below $1.00, which rarely occurs, although it
occurred in 2008, it is said that the MMF broke the buck.
MMFs are susceptible to runs because investors have an
incentive to redeem shares before others do when there is a
perception that the fund could suffer a loss. Thus when the
Reserve Primary Fund broke the buck, MMF investors
elsewhere also rushed to exit their positions, spreading fear
that MMFs, and even the broader financial system, were
vulnerable, regardless of whether actual losses occurred.


MMFs are regulated primarily under the Investment
Company Act of 1940 (P.L. 76-768) and Rule 2a-7
pursuant to the act. To mitigate MMFs' systemic risk, the
SEC reformed Rule 2a-7 in a multi-year process:

February 2010 SEC adopted certain Rule 2a-7
amendments to strengthen MMF liquidity.
March 2011 SEC proposed rules to eliminate certain
references to credit ratings in MMF reforms. The rules were
re-proposed in July 2014 and adopted in September 2015.
June 2013 SEC proposed rules to convert institutional
prime and institutional municipal MMFs to floating NAV.
March 2014 SEC issued multiple MMF economic studies
to solicit public comments.
July 2014 SEC finalized the 2014 MMF reform.
October 2016 SEC MMF reform became effective.

The main types of MMFs are (1) municipal, also referred to
as tax-exempt, which invest in national or state municipal


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