Daily Links Archives: February, 2013

The FDIC's latest Quarterly Banking Profile, which says, "The increase in noninterest income and reduction in loss provisions helped offset a $2.7 billion (2.5 percent) year-over-year decline in net interest income.... Total deposits increased by $313.1 billion (3 percent), as deposits in domestic offices posted a record $386.8 billion (4.3 percent) increase. Most of the growth consisted of large denomination deposits. Balances in accounts of more than $250,000 increased by $348.5 billion (8.2 percent). Uninsured deposit balances increased by $252.7 billion (12.7 percent), while balances in noninterest-bearing transaction accounts above the basic FDIC coverage level of $250,000 that had temporary full FDIC coverage through the end of 2012 increased by $49.5 billion (3.3 percent). Banks reduced their nondeposit liabilities by $76.9 billion (3.7 percent), and their foreign office deposits by $73.7 billion (5.1 percent)."

Bloomberg features an editorial by former SEC Chairman Arthur Levitt, entitled, "SEC Missed Chance on Money Funds, Should Step Aside Now." He says, "A former member of the U.S. Securities and Exchange Commission recently asked me to co-sign a letter urging a federal oversight body to refrain from taking regulatory action normally left to the SEC. I believe deeply in the independence of the agency I once led, but in this case, I could not place my loyalty to the organization above the larger goal of protecting individual investors. So I refused to sign. Every regulatory agency operates with a core mandate, and the SEC's is clear: Promote healthy and well-functioning markets, and protect investors through appropriate regulations and enforcement actions. The SEC must always place that mission above all other goals, including its own sovereignty and independence. When it doesn't, others may have to. At stake are much-needed and overdue reforms to money- market mutual funds, which hold $2.5 trillion. These funds were at the heart of the 2008 financial crisis. When the Reserve Primary Fund "broke the buck," in which the value of a share fell below $1, investors realized they would get less than $1 back for every $1 invested. The result was a run on all money-market funds, significant cash hoarding, the evaporation of short-term credit to even the best borrowers, and some of the worst days our economy has ever seen." See also, "SEC to Host Credit Ratings Roundtable," which will hold the event "on May 14 in response to a recent staff report on credit ratings and related matters." See too the recent "Report to Congress on Assigned Credit Ratings."

FSCO just posted a "Comment from Former Chairmen, Commissioners, and Senior Staff of the U.S. Securities and Exchange Commission", which says, "The undersigned are former Chairmen, Commissioners, and Senior Staff of the U.S. Securities and Exchange Commission (SEC or the Agency), spanning five decades of SEC service in both Democratic and Republican Administrations. `We write to urge you—individually and collectively as members of the Financial Stability Oversight Council (FSOC or the Council) -- to respect the jurisdiction, independence, subject-matter expertise, and regulatory processes of independent agencies such as the SEC. Although the timing of this letter is triggered by the Council's proposed recommendations to the SEC regarding regulation of money market mutual funds, this letter is not intended to, and does not, express a position on the substance of the specific proposals recommended by FSOC, or on any action taken, or refrained from being taken, by the SEC. The undersigned have varying views on certain substantive aspects of the regulation of money market mutual funds, but are of a single, adverse view of the process that FSOC has employed with respect to the SEC's regulation of money market mutual funds.... The SEC has had exclusive jurisdiction over securities regulation since 1934, and we can attest to the fact that significant decisions by the Commission receive thoughtful, objective consideration, and that the SEC possesses the specific expertise and historical perspective necessary to resolve the complex issues that arise relating to the securities markets. The SEC's oversight of money market mutual funds is no exception. In August 2012, a bipartisan majority of the Commission determined there was insufficient data at that time on which to base approval of further changes to the Agency's long-standing regulatory regime of money market mutual funds, a regime that was strengthened by additional SEC rules recently, in 2010. The statements of individual Commissioners -- that they were not ready to act without further data -- demonstrated thoughtful consideration of a serious issue, and a desire to obtain additional data to support ultimate conclusions, something the SEC is required to do by statute.... We urge the Council to defer to the SEC, which is fully equipped with the expertise and data necessary to exercise its role as the primary regulator of money market mutual funds."

Europe's ESRB, or European Securities Rulemaking Board published a "Recommendation of the ESRB of 20 December 2012 on funding of credit institutions," last week, which recommended a mandatory move to floating NAVs for all European money funds. It says under "Recommendation A -- Mandatory move to variable net asset value," "The Commission is recommended to ensure that the relevant Union legislation: 1. requires money market funds (MMFs) to have a fluctuating net asset value; 2. requires MMFs to make general use of fair valuation and to restrict the use of amortised cost accounting to a limited number of predefined circumstances." A summary from Sweden's Riksbank entitled, "The ESRB: bank funding and the regulation of money market funds" tells us, "The European Systemic Risk Board (ESRB) has published two recommendations. The first concerns bank funding and is based on the ESRB's assessment that even secured funding can pose risks to financial stability. The second recommendation aims to reduce the systemic risks that certain types of money market fund can give rise to.... The ESRB's second recommendation aims to reduce the systemic risks arising from money market funds. The recommendation mainly applies to money market funds with a constant net asset value (CNAV). During the financial crisis, these funds were subject to bank runs. This led to major disruptions on the money market which in turn exacerbated the financial crisis. Several financial institutions that offered money market funds through their fund management companies were also forced to inject money to protect unit holders who had invested in these funds. This undermined the financial standing of these financial institutions. To counteract the risk of such situations arising again, global standards for the regulation of money market funds have been drawn up. This has been done by the Financial Stability Board (FSB) together with the International Organization of Securities Commissions (IOSCO). The ESRB's recommendation calls on the European Commission to support the implementation of these standards within the EU. The ESRB recommends the prohibition of money market funds that offer CNAVs. The ESRB also recommends the introduction of stricter requirements for reporting and liquidity management in money market funds. At present there are no money market funds with a constant net asset value in Sweden. However, other parts of the recommendation will have consequences for the Swedish money market funds."

The ICI's weekly "Money Market Mutual Fund Assets", the broadest collection of money fund assets, shows money market mutual fund assets falling for the 6th straight week. The release says, "Total money market mutual fund assets decreased by $23.83 billion to $2.657 trillion for the week ended Wednesday, February 20, the Investment Company Institute reported today. Taxable government funds decreased by $8.13 billion, taxable non-government funds decreased by $16.36 billion, and tax-exempt funds increased by $670 million.... Assets of retail money market funds increased by $540 million to $912.43 billion. Taxable government money market fund assets in the retail category increased by $400 million to $196.57 billion, taxable non-government money market fund assets increased by $410 million to $518.26 billion, and tax-exempt fund assets decreased by $270 million to $197.61 billion.... Assets of institutional money market funds decreased by $24.36 billion to $1.745 trillion. Among institutional funds, taxable government money market fund assets decreased by $8.52 billion to $718.36 billion, taxable non-government money market fund assets decreased by $16.77 billion to $944.04 billion, and tax-exempt fund assets increased by $940 million to $82.50 billion." Money fund assets have declined by $58.9 billion since the week ended January 9th; they'd risen by $79.5 billion from Dec. 19 through Jan. 9 and by $90 billion from Oct. 31 through Dec. 19.

WSJ writes "Feuding Over Fund Collapse Drags On". It says, "U.S. securities regulators last November suffered a major setback in their civil trial against money-market mutual-fund inventor Bruce Bent Sr. and his son, but the two sides are still going at each other. Despite failing to prove fraud charges, the Securities and Exchange Commission is taking the unusual step of seeking $130 million in penalties from the Bents' former asset-management firm, whose flagship Reserve Primary Fund "broke the buck" in 2008 and ignited a crisis in the money-fund industry. The agency also is asking for a new jury trial to hear the fraud charges again, according to court documents. That isn't all. The SEC wants Mr. Bent's son, Bruce Bent II, 46 years old, to pay $1.3 million as punishment for the jury's finding that he was liable for negligence." See also yesterday's WSJ on "shadow banking" ("Too Big to Fail Casts Long Shadow").

Bloomberg writes "Goldman, BlackRock Reopen Euro Money Funds as Yields Rise". It says, "Goldman Sachs Group Inc. (GS) joined BlackRock Inc. (BLK) in reopening euro-denominated money-market funds to new clients as yields on the safest debt rose. BlackRock, the world's biggest money manager, lifted a restriction on new investment in its 17.7 billion-euro ($24 billion) Institutional Euro Liquidity Fund this month, Mark Stockley, the firm's head of international cash sales, said in an interview in London on Feb. 14. Goldman reopened its Euro Government Liquid Reserves fund to new subscriptions last week, spokeswoman Anisha Patel said by phone." In other "offshore" money funds news, a press release entitled, "J.P. Morgan Asset Management to publish market-based net asset values (NAVs) for three liquidity funds in its European range," said last week, "J.P. Morgan Asset Management today announced that three of its Luxembourg-domiciled European money market funds will begin to disclose their market-based NAVs per share (also known as Shadow NAVs) on a daily basis. This additional disclosure will provide investors with greater transparency regarding the Market-Based NAV's fluctuation. The Market-Based NAV will not impact the price at which shareholders will deal in the funds. Distributing classes will continue to transact at $1 per share, and accumulating classes will transact at the daily price disclosed on the website. This follows a similar recent announcement relating to the firm's US money market funds." Finally, see FT's "Call for money market reforms".

The Chamber of Commerce's Center for Capital Markets Competitiveness sent a letter to SEC last week on a floating NAV. It says, "We understand that the Securities and Exchange Commission ("SEC") is working toward a proposal that seeks to enhance the safety and soundness of MMMFs and may be considering concepts included in the Financial Stability Oversight Council's ("FSOC") proposed recommendations for MMMF reform. One of FSOC's proposed alternatives is the adoption of floating net asset values ("NAVs") along with the elimination of amortized cost accounting that facilitates a stable net asset value. Corporate treasurers and other investors, however, continue to express concerns regarding a floating net asset value because it eliminates a primary benefit of money market mutual fund investments while introducing a myriad of complex and costly accounting, tax, and operational obstacles. While we continue to believe that a floating NAV is not the right way to prevent perceived run risks, a floating NAV rule that does not fully address the accounting, tax, and operational changes needed to make it work would simply make the product unusable. Any regulatory action by the SEC incorporating a floating NAV into Rule 2a-7 should be done in concert with other standard-setting, regulatory, and legislative bodies whose actions may be necessary to ensure the continued utility and viability of MMMFs. The SEC by itself cannot make a floating NAV work without rendering the utility of MMMFs useless. It is therefore incumbent on the SEC to work jointly with other bodies to ensure all issues are addressed before any rule change is adopted."

ICI's latest "Money Market Mutual Fund Assets" shows the fifth straight week of asset declines for money funds. It says, "Total money market mutual fund assets decreased by $12.32 billion to $2.679 trillion for the week ended Wednesday, February 13, the Investment Company Institute reported today. Taxable government funds increased by $600 million, taxable non-government funds decreased by $9.93 billion, and tax-exempt funds decreased by $2.99 billion." ICI also issued a "Viewpoint, entitled, "ICI Responds to Letter on Money Market Funds from Federal Reserve Bank Presidents," which says, "Today, ICI made the following statement in response to a comment letter on money market fund reforms filed with the Financial Stability Oversight Council (FSOC) by the presidents of the 12 regional Federal Reserve banks. We welcome the Federal Reserve Bank presidents' recognition that different types of money market funds have distinct risk profiles and had different investor redemption experiences during the financial crisis. It is abundantly clear that there is no case for further, fundamental changes in Treasury, government, or tax-exempt money market funds. ICI firmly believes that any money market fund issues should be considered and directed by the Securities and Exchange Commission, which has direct authority over mutual funds, including money market funds. For the reasons detailed in ICI's comment letter to FSOC, we believe a temporary redemption gate and liquidity fee for prime money market funds is the only proposal under discussion that would stop redemptions during extreme market stress. FSOC's other proposals would not accomplish regulators' stated goals and would harm investors and the economy." Finally, in other news, a press release entitled, "FEI Committee Submits Comments to Financial Stability Oversight Council on Proposed Money Market Fund Reform" says, "Financial Executives International (FEI), the association of choice for CFOs and other senior-level finance executives, today announced that its Committee on Corporate Treasury has filed a comment letter with the Financial Stability Oversight Council (FSOC) on the "Proposed Recommendations Regarding Money Market Mutual Fund Reform." FEI advocates the need to preserve the structure of money market mutual funds (MMF) and has concerns with the three proposed reform options, which would require funds either to float their value (Floating NAV), create a capital buffer with certain investor redemption delays (NAV Buffer and Minimum Balance at Risk), or implement a capital buffer combined with other measures (NAV Buffer and Other Measures). The comment letter states the committee's continued belief that the reform options are unnecessary and may have a dampening effect on the money market industry and then a collateral effect on corporate treasurers and their companies."

The Government Finance Officers Association (GFOA) was joined by a host of other organizations in writing a comment to FSOC on its money fund reform proposals. GFOA writes, "The fixed NAV is a fundamental feature of money market mutual funds. As investors, many state and local governments look to MMMFs as part of their cash management practice. In the Government Finance Officers Association's Best Practice, "Use of Various Types of Mutual Funds by Public Cash Managers," governments are encouraged to look to money market funds for short-and medium-term investments, with appropriate cautions. One of the critical reasons for this recommendation is the fixed NAV feature found in these products. In fact, many governments have specific policies that mandate that they invest in products with stable values. These requirements and the popularity of MMMFs as a cash management tool reflect the fact that these funds are highly regulated, have minimal risk, and are easily booked by the investor. State and local governments currently have $127 billion invested in these funds according to the Federal Reserve Bank. Additionally, changing the fundamental feature of MMMFs from a fixed NAV to a floating NAV would dampen investor demand for municipal securities and therefore could deprive state and local governments and other borrowers of much-needed capital. Consider that MMMFs are the largest investor in short-term municipal bonds, holding 73% of all outstanding short-term bonds equaling nearly $271 billion. Creating a marketplace where the NAV changes from fixed to floating would make MMMFs far less attractive to investors, thereby limiting the ability of money market funds to purchase municipal securities. Losing this vital investing power could lead to higher debt issuance costs for many state and local governments across the country." The letter was signed by these organizations: American Public Power Association, Council of Infrastructure Financing Authorities, Government Finance Officers Association, International City/County Management Association, International Municipal Lawyers Association, National Association of Counties, National Association of Health and Educational Facilities Finance Authorities, National Association of Local Housing Finance Agencies, National Association of State Auditors, Comptrollers and Treasurers, National Association of State Treasurers, National Council of State Housing Agencies, National League of Cities, and the U.S. Conference of Mayors.

Fitch Ratings published the brief "FDIC-Backed Deposit Programs May Grow", which says, "The use of programs that pool Federal Deposit Insurance Corporation-insured bank deposits will likely grow this year, according to Fitch Ratings. These programs offer government guarantees on large dollar deposits by splitting them into smaller deposits among a large number of participating banks, therefore qualifying for Federal Deposit Insurance Corporation (FDIC) protection. Institutions participating in these programs could be national association banks, but are mostly small local banks with a limited depositor base and constrained access to the capital markets, thus presenting credit risk to which investors have to be mindful. Fitch believes that bank failure remains the primary risk. According to the FDIC data, 51 U.S. banks failed in 2012. Should a program member bank fail, the deposit obligations are expected to be transferred to a healthy institution by the FDIC.... Nonetheless, providing both meaningful safety and yield, these programs remain attractive facilities for conservative investors. For example, both the Certificate of Deposit Account Registry Service and the Federally Insured Cash Account offer full FDIC insurance coverage and yield in excess of the U.S. Treasury rate of comparable maturity. There are other programs that offer similar services. Among conservative investors, local government investment officers may increase their allocations to these programs, according to one Fitch-rated government investment pool. With the expiration of the Transaction Account Guarantee program on Dec. 31, 2012 (which provided an unlimited FDIC insurance for non-interest bearing deposits), this pool increased its allocations to both programs to nearly 13% of its portfolio in December 2012 from just under 3% a year ago."

The Mutual Fund Directors Forum is the latest to file a Comment on the FSOC's "Proposed Recommendations Regarding Money Market Mutual Fund Reform". The independent fund directors' organization writes, "The Commission has not abdicated its responsibilities with respect to money market funds. Although the Commission did not take additional action in 2012, the Commission did adopt significant amendments to the regulations governing money market funds in 2010 and continues actively to analyze the impact of these amendments, both on the risks posed by individual funds and on the nature of the risk that these funds pose to the broader financial system. Moreover, recent comments and actions by individual Commissioners demonstrate that the Commission is continuing to work with the industry and internally to identify and analyze varying approaches to the regulation of money market funds. Indeed, regulatory approaches not fully addressed in the Proposed Recommendations, such as the use of liquidity fees, are now being actively discussed in the industry..... [W]e very much appreciate the opportunity to comment on the Council's Proposed Recommendations on behalf of our independent director members. As our comments, and the likely comments of many other industry participants demonstrate, while money market funds play a key role in our financial markets and provide investors an important competitive option for managing their cash and liquidity needs, the extent to which money market funds pose a real systemic risk to the financial system remains unclear. Many recent studies, including the SEC staff's recent report, are positive first steps in attempting to answer this question. We therefore urge the Council and other regulators to continue to analyze these questions before imposing costly new regulations on the money market fund industry that will render these funds a less competitive, less compelling option for their investors." Note: Comments to FSOC are due by this Friday, February 15.

Wells Fargo Advantage Funds latest monthly Commentary says, "After a quiet end to 2012 that was largely due to typical yearend cash buildup and uncertainty about the fiscal cliff, the tone changed markedly as we rang in the new year. Spurred by even lower yields in the repurchase agreement (repo) and government markets caused by the end of the Federal Reserve's (Fed's) Operation Twist and improved market sentiment, market participants greeted issuers with open pocketbooks. Inflows into prime funds, apparently caused by a need to place excess liquidity over year-end, led to a larger appetite for prime instruments. Then, as sure as spring follows winter, the increased competition for commercial paper (CP) and certificates of deposit in the face of a lower overall supply caused yields on those instruments to decline. The outstanding amount of prime securities in December decreased as issuers largely sat on the sidelines after having addressed their funding for the month; that trend reversed in January as total outstanding CP increased by more than $100 billion. Non-U.S. financial issuers have been one of the few bright spots in terms of supply. While the total amount of CP outstanding has fallen by half since its peak in August 2007 and total asset-backed CP has declined by 75%, issuance by non-U.S. financials has risen by more than onethird. Total financial CP outstanding has increased roughly $65 billion since July 2012. Of that amount, more than 70%, or $46 billion, was from non-U.S. issuers."

Capital Advisors had its FSOC Comment Letter posted recently. It includes the paper, "A Floating Net Asset Value Substitute, Reintroducing the Dual-NAV Proposal with Shadow NAVs," and says, "We believe that mandatory disclosure of daily market value NAVs will be a significant step toward better risk transparency in money market funds. It is functionally equivalent to the FSOC/SEC's floating NAV proposal without the unnecessary operational, accounting and tax complexities. When applied along with objective liquidity gates and/or reasonable NAV buffers, the approach should sufficiently reduce systemic concerns with money market funds and address major issues from key constituents. We are opposed to resetting the unit NAVs to $100.00; however, we believe more work is needed for market value NAVs to be truly useful. We think shareholders could further benefit from analytical research that incorporates market value NAVs, but, at the same time, we urge regulators to address shareholder risk by enforcing more look-through shareholder concentration and asset flow disclosure.... Back in April 2012, we proposed to the Securities and Exchange Commission (SEC) a floating Net Asset Value (NAV) recommendation that requires money market mutual funds to report daily market value-based NAVs up to the 4th decimal place, but allows shares to be traded at NAVs rounded to the 2nd decimal place. The premise is to preserve the transactional utility of the $1.00 NAV while making share value volatility fully transparent. In essence, we believe in NAV stability through market disciplines and sound risk management rather than through amortized cost accounting or sponsor capital support. Forcing NAVs to change every day not only is cumbersome, but also ineffective, in our opinion."

The U.S. Department of the Treasury's latest "Treasury Assistant Secretary for Financial Markets Matthew Rutherford February 2013 Quarterly Refunding Statement", says, "The U.S. Department of the Treasury is offering $72 billion of Treasury securities to refund approximately $64.0 billion of securities maturing on February 15, 2013. This will raise approximately $8.0 billion of new cash.... Treasury expects to keep note and bond auction sizes stable in the coming months. Treasury believes that the current coupon issuance schedule and offering sizes for notes and bonds are adequate to address forecasted borrowing needs over the near term. As is typical during the tax season, in the coming weeks there will be a seasonal increase in borrowing needs ahead of the April 2013 filing deadline. Treasury plans to address this seasonal borrowing need through increases in regular bill auction sizes and cash management bills. Going forward, Treasury will continue to provide guidance to market participants regarding any changes in the fiscal outlook that might impact the government's financing needs." They comment on "Floating Rate Notes (FRNs)," "At the August 2012 Quarterly Refunding, Treasury announced plans to develop a floating rate note (FRN) program to complement our existing suite of securities and to help achieve our objective of financing the government at the lowest cost over time. On December 5, 2012, Treasury published an Advance Notice of Proposed Rulemaking (ANPR) soliciting public comments on the design details and terms and conditions relevant to the issuance of floating rate securities. The ANPR comment period closed on January 22, 2013. Treasury is currently reviewing the comment letters that have been received. We plan to issue a final rule on floating rate notes in the coming months, with the first FRN auction still estimated to be about a year away. This timeframe reflects Treasury's best estimate for implementing required auction regulations and IT systems modifications. Treasury will continue to provide additional information on the details of the program." Finally, note that Treasury Assistant Secretary for Financial Markets Matthew Rutherford is scheduled to speak at our upcoming Crane's Money Fund Symposium, which will be held June 19-21, 2013, at the Baltimore Hyatt Regency.

Last month, the No-1 yielding Retail money market fund, the Flex-fund Money Market Fund was renamed as the Meeder Money Market Fund. The fund's prospectus supplement filing explains, "Effective December 31, 2012, The Flex-funds changed its name to Meeder Funds. Therefore, the Prospectus and Statement of Additional Information ("SAI") dated April 30, 2012 are revised as follows: All references in the Prospectus and SAI to The Flex-funds® are hereby amended to read Meeder Funds."

A press release entitled, "Clearwater Analytics Clients Ready for Accounting Implications of Any Possible Money Market Fund Changes," and subtitled, "Daily MMF Mark-to-Market Reporting Capabilities Already in Place With SaaS Solution," tells us, "The decision by several major money market fund managers to publish the daily net asset value (NAV) of their funds signals potential disruption in the Money Market Fund (MMF) industry. While regulators have not required investors to book a floating NAV instead of a $1 per share price, a potential shift to daily mark-to-market reporting would introduce administrative, accounting, and regulatory complexities. However, clients of Clearwater Analytics, the leading software-as-a-service provider of investment analytics and accounting, are already prepared for any possible changes from an MMF accounting perspective. Daily reporting of unrealized gains/losses, regulatory disclosures, and other downstream consequences of a floating NAV can easily be accommodated by Clearwater's powerful, proprietary investment accounting solution. Clearwater already provides its clients with daily investment data, including accruals, unrealized gains/losses, and changes in cost values, as part of its holistic solution." Scott Erickson, Director of Product Management, "It's important that our clients know they can rely on Clearwater's ability to properly account for and report on their MMF investments. Any anticipated changes in the MMF industry should not faze Clearwater clients from an accounting perspective because we've taken careful measures to anticipate any scenario."

MarketWatch writes "SEC chief: Money-market fund reform high on agenda". The piece says, "Reform of the $2.7 trillion money-market fund industry is one of the top issues that the Securities and Exchange Commission will tackle in the coming months, agency chairman Elisse Walter told reporters Friday." They quote Walter, "We have a number of things that are number 1 and number 2 on the agenda and we are working very hard on money-market funds." The MarketWatch brief explains, "Walter said after speaking to a small business advisory panel. She added that commissioners are working "very well together" and the agency is getting valuable input from the industry." "The whole dynamic around that project has changed," she told the website. It adds, "White also said she supported Mary Jo White, a former U.S. attorney, who President Obama nominated last week to head the agency."

Bloomberg writes "Euro Money Funds Preparing for Yields Below Zero, Fitch Reports". The article says, "More than half of the euro funds represented by the Institutional Money Market Funds Association are changing share structures so they can operate if yields fall below zero, Fitch Ratings said. Funds with almost 50 billion euros ($67 billion) of assets have adopted, or said they will adopt, changes that allow them to pass losses to investors by reducing the number of shares they own, according to Fitch. Without the change, record-low yields on the debt the funds buy will threaten their fixed-share price and force them to shut. JPMorgan Chase & Co. (JPM) said in October it was replacing two stable net asset value euro money-market funds with variable share classes. RBS Asset Management Ltd. is adopting the changes for funds with 9.8 billion pounds ($15.4 billion) under management while Morgan Stanley (MS) has also announced similar structures." Fitch comments, "Investors have been accepting of this. We expect more fund complexes will follow suit." Crane Data's Money Fund Intelligence International shows the 65 Euro money market funds yielding 0.03% on average (Crane Euro MMF Index 7-Day Yield) and holding 90.7 billion in Euro as of Jan. 30. See also, ICI's latest weekly "Money Market Mutual Fund Assets".

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