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Regulatory Update: 2014 Money Fund Reform
Presentation to Iowa TMA Regulatory Update: 2014 Money Fund Reform Jim Gilligan, CTP, FP&A Assistant Treasurer Great Plains Energy Inc. September 9, 2014 AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Overview of Changes Combination of reform Gov’t fund changes
Floating NAV Gates and fees Gov’t fund changes Retail fund changes Reporting changes Time horizon Tax changes Treasury implications AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Floating NAV & Gates/Fees
Type of Fund Net Asset Value (NAV) Redemption Gates Redemption Fees Accounting Method Institutional Prime Floating Yes NAV U.S. Treasury Stable Opt In Amortized Cost Government Institutional Muni/Tax Exempt Retail Floating NAV is non discretionary Gates and Fees are discretionary by the Board of the Fund If weekly liquidity assets fall below 30% of the Fund’s total assets Board can implement up to a 2% Fee Suspend redemptions (lower a gate) for up to 10 business days Only gate up to10 business days per 90 day period Mandatory fee of 1% if weekly liquidity assets fall below 10% of total assets AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Government Fund Changes
Re-defined as 99.5%* of total assets invested in: Cash Government securities Repos collateralized by gov’t securities Gates and Fees are: At the discretion of the fund board with investor notification Special reporting if NAV falls below $0.9975 __________________ * Was 80% AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Retail Fund Changes Retail Investor Not related to asset size
Now defined as a natural person Tied to Social Security Number Not related to asset size Share classes/structure could change Special reporting if NAV falls below $0.9975 AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Reporting Changes Floating NAV calculated to 1/100 of a penny ($0.0001) for Prime and Muni Funds Fund disclosure if <10% weekly liquidity Daily reporting of: Daily and weekly liquid assets Net shareholder flows Market based NAV’s Imposition of Fees and Gates Sponsor support of the fund New material event disclosure (on Form N-CR) Disclosure of Sponsor support for prior 10 yrs Form PF- private liquidity funding to report same as N-MFP AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Reporting Changes Cont’d
5% issuer diversification limit requires affiliated entities to be treated as a single issuer 10% limit for guarantors of demand feature providers including Asset Backed Guarantors 15% for Muni funds Enhanced stress testing Removal of Credit Ratings reference re-proposed Discretion of the board to determine appropriate securities Tier I/Tier II restriction removed AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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All Other (Divers, PF, N-MFP, etc.)
Time Horizon Fund Floating NAV Gates/Fees N-CR All Other (Divers, PF, N-MFP, etc.) Prime 2 years 9 months 18 months Gov’t/Treas n/a (if opt in) Muni Retail Clock starts when rules are published in Federal Register AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Tax Changes NAV Method vs. Amortized Cost For More Information:
Aggregated reporting of sales Realized gain/loss is “short term” Not subject to “Wash Sale” Rules For More Information: AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Treasury Implications
Investment policy considerations Board approval and education Floating NAV Gates/Fees Accounting considerations Revised fund due diligence Discussions with your fund manager Discussion with your fund sponsor/bank Credit rating’s reform How tax reporting will be delivered Bank product shift- more into CDs,TD’s? Rise of non 2a-7 products Basel III timing and reform timing AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Treasury Implications Cont’d
More discretion given to the fund board Offshore cash not subject to Money Fund Reform…. YET More than just money funds impacted- Money fund like products Consider other areas: DB, DC, Securities Lending, etc. Muni based investors need gov’t backing; limited options CP Issuers affected; dealer placed; alternate sources of funding Portal provider reporting changes - timing AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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(Percent of Organizations Currently Investing in Prime MMFs)
Action Will Occur (Percent of Organizations Currently Investing in Prime MMFs) Source: The AFP Liquidity Survey, Association for Financial Professionals AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Short-Term Investment Objective
Most Important Short-Term Investment Objective, (Percent of Respondents) Source: The AFP Liquidity Survey, Association for Financial Professionals AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Change in Allocation of Investments
Allocation of Short-Term Investments, (Mean Percent Distribution) Source: The AFP Liquidity Survey, Association for Financial Professionals AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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Money Fund Selection Could Change
Source: The AFP Liquidity Survey, Association for Financial Professionals AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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For More Information SEC Information: Treasury/IRS Information:
Tom Hunt, CTP Director of Treasury Services Association for Financial Professionals SEC Information: Treasury/IRS Information: AFP, Association for Financial Professionals and the AFP logo are registered trademarks of the Association for Financial Professionals.
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