Blame it on Regulation Q.

Within the Glass-Steagall Act of 1933, Regulation Q used to impose a cap on the interest rates banks could pay on deposits. Over time, investors sought a better liquidity management solution and higher returns for their excess liquidity. Eventually, innovation took hold, and the regulated 2a-7 U.S. money market fund industry began to germinate in the 1970s, offering a balance of higher returns, $1 par share price and same-day liquidity.

Just as the emergence of money market funds more than four decades ago encouraged investors to consider a different approach to liquidity management, the SEC’s new money market fund regulations, which take effect in mid-October, should also mark a point of reflection for investors. We would encourage investors to consider the impact of these alterations, including the deteriorating purchasing power protection of money funds. We would also encourage those still allocated to money market funds (hopefully to a lesser degree), to look “under the hood” at the composition of fund holdings. At a glance, investors can see that all money market funds are not equal. Substantive differences in holdings can result in differences in net returns to investors over time, even though each of these funds is adhering to the same SEC regulatory requirements.

What to consider in money market funds

In an attempt to safeguard money market funds and remove previous structural deficiencies, the SEC regulations have refined what investments these funds can make. Government money market funds, which can still offer investors the stability of a fixed $1/share net asset value, now need to hold 99.5% of assets in government-related securities – namely, Treasury bills, agency discount notes and repurchase agreements, or repos. As with other core fixed income strategies, these funds’ largest risk will now be interest rate risk.

To successfully navigate this risk, asset managers need to have a robust investment process to analyze their expectations for interest rates/monetary policy against what is priced into the market, as well as compelling views on global macroeconomic trends. Without these, an investment manager will likely leave valuable basis points of income on the table.

Another consideration for investors should be the size and scope of the investment manager’s capabilities. The skillset, expertise (even beyond money markets) and size of the manager should be focal points rather than the size of the fund itself. Firm size can mean greater access to the repo market in particular, and repos will be a precious commodity: They have historically offered higher yields than short-dated Treasury bills and agency discount notes, and the yield differential between overnight repos and three-month T-bills is currently at its widest in years (see Figure 1).

Moreover, different types of repurchase agreements can potentially yield even more: Delivery-versus-payment (DVP) repos, which PIMCO generally favors, have historically offered superior returns and collateral protection for investors compared to the tri-party custodian alternative, which the majority of larger money market fund complexes employ. Thus, money-fund managers that have greater access to (DVP) repo balance sheet can potentially earn higher yields.

In addition, as banks continue to reduce their footprint in the repo market due to increased capital requirements, the aggregate amount of repos outstanding has decreased by more than $2.5 trillion since 2008. The remaining market participants are increasingly deciding with whom and how much to trade based on several factors, including relationship size – not fund size. Asset managers who engage repo providers on both sides of the “balance sheet” – i.e., both lend cash and borrow cash ‒ will be able to better negotiate rates for clients, as they can diversify their exposures and limit them to those offering the best levels. In essence, most money market funds are price-takers, accepting whatever rate is offered by financial intermediaries due to limited negotiating power. In contrast, larger asset managers with broader scope in the global markets have the potential to garner more repo allocations and thus higher yields.

Finally, how a fund is managed is more important than ever. Actively managed funds can take advantage of opportunities for higher yields as they arise, without the constraints of mirroring their benchmarks, which passive strategies typically do. As a result, they may be better able to preserve investors’ purchasing power in the low interest rate environment, where every basis point counts.

PIMCO’s actively managed Government Money Market Fund produced a net yield of 0.33% versus 0.17% for the government money market fund universe, based on Crane’s Government Institutional MF Index, as of 30 September 2016.

Looking closely at short-term liquidity allocations

With the upcoming implementation in October of money market reform measures as mandated by the SEC, PIMCO encourages investors to also review the composition of their liquidity strategy ‒ both in terms of risks, given the new regulatory framework, and opportunities to earn more income, given the altered structural landscape. Because money market funds offering $1 NAVs will have limited options for increasing yield under the new regulations, we continue to advocate a “three-tier” approach to liquidity management.

For the first tier – immediate liquidity needs – money market funds are well suited. The second and third tiers, for holdings of more than three months, can then be invested in short-term liquidity alternatives that aim for higher yields with more diversified risk profiles. This framework not only utilizes same-day traditional liquidity vehicles like money market funds but also employs actively managed short-term and low-duration bond strategies in an effort to maximize yield and actively navigate changing liquidity conditions in the broader marketplace.

DISCLOSURES

Investors should consider the investment objectives, risks, charges and expenses of the funds carefully before investing. This and other information are contained in the fund’s prospectus and summary prospectus, if available, which may be obtained by visiting pimco.com or by contacting your investment professional or PIMCO representative.

A word about risk:

Investing in the bond market is subject to risks, including market, interest rate, issuer, credit, inflation risk, and liquidity risk. The value of most bonds and bond strategies are impacted by changes in interest rates. Bonds and bond strategies with longer durations tend to be more sensitive and volatile than those with shorter durations; bond prices generally fall as interest rates rise, and the current low interest rate environment increases this risk. Current reductions in bond counterparty capacity may contribute to decreased market liquidity and increased price volatility. Bond investments may be worth more or less than the original cost when redeemed. Certain U.S. Government securities are backed by the full faith of the government, obligations of U.S. Government agencies and authorities are supported by varying degrees but are generally not backed by the full faith of the U.S. Government; portfolios that invest in such securities are not guaranteed and will fluctuate in value.

You could lose money by investing in the Fund. Although the Fund seeks to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. An investment in the Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. The Fund's sponsor has no legal obligation to provide financial support to the Fund, and you should not expect that the sponsor will provide financial support to the Fund at any time.

This material contains the current opinions of the manager and such opinions are subject to change without notice. This material has been distributed for informational purposes only and should not be considered as investment advice or a recommendation of any particular security, strategy or investment product. Information contained herein has been obtained from sources believed to be reliable, but not guaranteed. No part of this material may be reproduced in any form, or referred to in any other publication, without express written permission. PIMCO is a trademark of Allianz Asset Management of America L.P. in the United States and throughout the world.

PIMCO Investments LLC, distributor, 1633 Broadway, New York, NY 10019, is a company of PIMCO.

Helping advisors enable clients to achieve their financial goals

As New SEC Rules Take Effect, It May Be Time to Look "Under the Hood" of Your Money Market Fund.

What to consider in money market funds

Looking closely at short-term liquidity allocations

DISCLOSURES

As New SEC Rules Take Effect, It May Be Time to Look "Under the Hood" of Your Money Market Fund.

What to consider in money market funds

Looking closely at short-term liquidity allocations

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