The SEC published its latest quarterly "Private Funds Statistics" report recently, which summarizes Form PF reporting and includes some data on "Liquidity Funds," or pools which are similar to but not money market funds. The publication shows overall Liquidity fund assets were lower in the latest reported quarter (Q1'24) at $331 billion (down from $352 billion in Q4'23 but up from $313 billion in Q1'23). We also again briefly review the part of the SEC's MMF Reforms which addresses "Amendments to Form PF Reporting Requirements for Large Liquidity Fund Advisers" and which went into effect over the summer, below. (Note: Register ASAP for our upcoming Money Fund University, which will be held Dec. 19-20, 2024 in Providence, R.I. See you in Providence in 4 weeks!)
The SEC's "Introduction" tells us, "This report provides a summary of recent private fund industry statistics and trends, reflecting data collected through Form PF and Form ADV filings received through October 04, 2024. Form PF information provided in this report is aggregated, rounded, and/or masked to avoid potential disclosure of proprietary information of individual Form PF filers. This report reflects data from First Calendar Quarter 2022 through First Calendar Quarter 2024 as reported by Form PF filers." (Note: Crane Data believes the largest portion of these liquidity fund assets are securities lending reinvestment pools.)
The tables in the SEC's "Private Funds Statistics: First Calendar Quarter 2024," with the most recent data available, show 73 Liquidity Funds (most of which are "Section 3 Liquidity Funds," which are Liquidity Funds from advisers with over $1 billion total in cash), up 1 from last quarter and up 3 from a year ago. (There are 48 Section 3 Liquidity Funds out of the 73 Liquidity Funds.) The SEC receives Form PF reports from 37 Liquidity Fund advisers (19 of which are Section 3 Liquidity Fund advisers), unchanged from last quarter and up 4 from a year ago.
The SEC's table on "Aggregate Private Fund Net Asset Value" shows total Liquidity Fund assets at $331 billion, down $21 billion from Q4'23 and up $18 billion from a year ago (Q1'23). Of this total, $325 billion is in Section 3 (large manager) Liquidity Funds. The SEC's table on "Aggregate Private Fund Gross Asset Value" shows total Liquidity Fund assets at $339 billion, down $22 billion from Q4'23 and up $19 billion from a year ago (Q1'23). Of this total, $333 billion in is Section 3 (large manager) Liquidity Funds.
A table on "Beneficial Ownership for Section 3 Liquidity Funds" shows $118 billion is held by Other (36.4%), $56 billion is held by Unknown Non-U.S. Investors (17.1%), $54 billion is held by Private Funds (16.6%), $12 billion is held by Insurance Companies (3.7%) and $3 billion is held by Non-Profits (1.1%).
The tables also show that 66.6% of Section 3 Liquidity Funds have a liquidation period of one day, $309 billion of these funds may suspend redemptions, and $282 billion of these funds may have gates. WAMs average a short 38.9 days (50.5 days when weighted by assets), WALs are 53.5 days (71.7 days when asset-weighted), and 7-Day Gross Yields average 5.20% (5.20% asset-weighted). Daily Liquid Assets average about 54.5% (47.0% asset-weighted) while Weekly Liquid Assets average about 62.1% (61.1% asset-weighted).
Overall, these portfolios appear shorter with a heavier Treasury exposure than money market funds in general; a third of them (33.3%) are fully compliant with Rule 2a-7. When calculating NAVs, 72.9% are "Stable" and 27.1% are "Floating."
As we've mentioned before, in July 2023, when the SEC's Money Market Fund Reforms were passed, these also included "Amendments to Form PF Reporting Requirements for Large Liquidity Fund Advisers." The release explains, "Separately, the amendments will also modify certain reporting forms that are applicable to money market funds and large private liquidity funds advisers."
The "Fact Sheet" explains, "In addition, the Commission adopted amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, to require additional information regarding the liquidity funds they advise that is generally aligned with the amended reporting for money market funds. These amendments were proposed by the Commission in January 2022."
The full final rules tell us, "The Commission is also amending Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds to require additional information regarding the liquidity funds they advise. Liquidity funds are private funds that seek to maintain a stable NAV (or minimize fluctuations in their NAVs) and thus can resemble money market funds. The amendments to section 3 of Form PF will provide a more complete picture of the short-term financing markets in which liquidity funds invest and enhance the Commission's and the Financial Stability Oversight Council's ('FSOC') ability to assess short-term financing markets and facilitate our oversight of those markets and their participants. This, in turn, is designed to enhance investor protection efforts and systemic risk assessment. `We have consulted with FSOC to gain input on these amendments to help ensure that Form PF continues to provide FSOC with information it can use to assess systemic risk."
It adds, "In a January 2022 release proposing amendments to Form PF, the Commission proposed changes to section 3 of Form PF that were intended to require large liquidity fund advisers to report substantially the same information that the Commission had proposed money market funds to report on Form N-MFP. The proposed amendments to section 3 of Form PF included requirements for additional and more granular information regarding large liquidity fund operational information and assets, portfolio holdings, financing, and investor information as well as a new item concerning the disposition of portfolio securities. Consistent with the final amendments to Form N-MFP, we are adopting largely as proposed the amendments to section 3 of Form PF, with some modifications to better tailor the reporting to private liquidity funds and remain consistent with the final requirements for money market funds under amended Form N-MFP."
