In Andrew Cross and my series on Rule 18f-4, we noted that the SEC was rescinding Release 10666 and related no-action letters as of the compliance date for the rule (August 19, 2022). The release adopting 18f-4 also promised that the Division of Investment Management would review prior guidance and reconcile the guidance to the
Compliance
The Cost of Swing Pricing Too Often
This continues my series of posts on the SEC’s proposal to require money market funds with floating net asset values (“institutional money funds”) to implement swing pricing during any pricing period in which the fund has net redemptions. In this post, I consider the effects of swinging a price too frequently.
Swing Pricing and the Problem of Pricing Periods
This continues my series of posts on the SEC’s proposal to require money market funds with floating net asset values (“institutional money funds”) to implement swing pricing during any pricing period in which the fund has net redemptions. Having surveyed how institutional money funds are supposed to determine swing prices under the proposal, I am turning to when swing pricing would be required. First, I want to consider a unique feature of institutional money funds, namely that many funds calculate a floating net asset value per share (“NAV”) more than once a day. The proposed amendments would define the time from the calculation of one NAV to the next as a “pricing period.” Pricing periods pose two conflicting problems for swing pricing.
Money Fund Liquidity and Market Impacts
This continues my series of posts on the SEC’s proposal to require money market funds with floating net asset values (“institutional money funds”) to implement swing pricing during any pricing period in which the fund has net redemptions. Having address the estimated costs that institutional money funds must always include in their swing price, this post considers the “market impact factor” to be included when net redemptions exceed the market impact threshold. I suspect the SEC underestimated the difficulty of estimating market impact factors.
SEC Proposes Climate Disclosure Rules: 9 Things to Know
On Monday, the SEC announced its much anticipated proposal on climate-related disclosure for public companies. As our colleague Allison Handy explains in her Public Chatter blog, the proposal would require disclosure on climate-related risks financial statement metrics, including information on greenhouse gas emissions, weather-related and other natural events, operational resilience, and the company’s climate-related transition…
Components of Swing Prices—Taxes and Other Charges
This is another in my series of posts on the SEC’s proposal to require that money market funds with floating net asset values (“institutional money funds”) implement swing pricing during any pricing period in which the fund has net redemptions. This post continues the analysis of the estimated costs that an institutional money fund “must include, for each security in the fund’s portfolio” when determining any swing price. These costs are:
- Spread costs,
- Brokerage commissions,
- Custody fees, and
- Any other charges, fees, and taxes associated with portfolio security sales.
I cannot tell what this last bullet might include, so I will discuss two expenses that should not be included.
Components of Swing Prices—Custody Fees
This is another in my series of posts on the SEC’s proposal to require money market funds with floating net asset values (“institutional money funds”) to implement swing pricing during any pricing period in which the fund has net redemptions. This post continues the analysis of the estimated costs that an institutional money fund “must include, for each security in the fund’s portfolio” when determining any swing price. These costs are:
- Spread costs,
- Brokerage commissions,
- Custody fees, and
- Any other charges, fees, and taxes associated with portfolio security sales.
This post considers custody fees.
Components of Swing Prices—Spread Costs
This post begins a detailed consideration of the SEC’s proposal to require money market funds with floating net asset values (“institutional money funds”) to implement swing pricing during any pricing period in which the fund has net redemptions. I begin with the estimated costs that an institutional money fund “must include for each security in the fund’s portfolio” when determining any swing price, namely:
- spread costs,
- brokerage commissions,
- custody fees, and
- any other charges, fees, and taxes associated with portfolio security sales.
This post considers spread costs and brokerage commissions.
The Upshot of Swing Pricing
This is the fifth in my series of posts analyzing the SEC’s recent proposal to require money market funds with floating share prices (“institutional money funds”) to implement “swing pricing” for pricing periods in which the fund has net redemptions. This post completes the illustration from my last two posts and examines the impact of swing pricing on the fund and its shareholders.
An Illustration of Swing Pricing with Market Impact Factors
This is the fourth in my series of posts analyzing the SEC’s recent proposal to require money market funds with floating share prices (“institutional money funds”) to implement “swing pricing” for pricing periods in which the fund has net redemptions. This post continues the example from the previous post to illustrate how the proposal would address net redemptions exceeding the market impact threshold.