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Association for Financial Professionals Comment Letter to SEC on Money Market Reform Proposals (PDF)

"We oppose the proposal to remove the amortized valuation of prime institutional funds, thereby subjecting these funds to a floating net asset value (NAV). Doing so reduces corporate investors' interest in utilizing MMFs as a cash management and investment tool.... An AFP survey of financial professionals found that 56% of organizations would be less willing to invest in floating NAV money market funds, resulting in reduction or even elimination of MMF holdings."

Financial Pros Notch Win in Money Market Fund Tussle

"Over the course of the debate, [the Association had] argued that changes to MMF rules would greatly reduce investors' interest in utilizing MMFs as a cash management and investment tool, whether applied to all investors or just institutional investors. "

Geithner Gives New Life to Proposals for Regulation of Money-Market Funds

"In a letter to the Financial Stability Oversight Council (FSOC) on September 27, Geithner acknowledged that MMFs were a 'significant source of short-term funding for businesses' and agreed that MMFs 'provide an important cash management vehicle for both institutional and retail investors' but called for the FSOC to begin the process of regulating the funds in the event that the SEC is 'unwilling to act in a timely and effective manner'."

Corporate Treasurers Applaud SEC's Decision to Forgo Changes to Money Market Funds

"The potential disruption of $2.6 trillion of funding would likely have left corporate treasurers without a critical source of short-term capital, namely commercial paper, said Jim Kaitz, AFP's president and CEO."

Geithner, FSOC Mandate More Money-Market Fund Reforms

"The FSOC's three alternative recommendations include: Requiring MMFs to trade under a floating new asset value (NAV), thereby removing their current status fixed to a stable NAV of $1.00. Permitting MMFs to maintain a stable NAV, while holding a capital buffer of up to 1 percent of the fund's assets and requiring a marginal percentage be withheld from immediate investor redemption. Permitting MMFs to maintain a stable NAV, while holding a 3 percent buffer of the fund's assets for explicit loss-absorption, as well as additional measures, including diversification of fund investments. Following a 60-day public comment period, FSOC will issue a final recommendation to the SEC, requesting, once again, that the agency take action. If the SEC fails to do so, FSOC could exercise its authority to declare MMFs systemically important and place them under the oversight of the Federal Reserve."

Text of CIEBA Comments on DOL's Proposed Regulation on Default Investment Alternatives (PDF)

4 pages. Excerpt: CIEBA generally agrees with the proposed rules that a 'qualified default investment alternative' (QDIA) should be diversified and managed to reflect the level of risk appropriate to the participant's demographic characteristics. Such a blend of asset classes, including both capital appreciation and capital preservation vehicles, are most likely to increase retirement savings for 'defaulted' participants.

Single-Employer Program Is Healthy But Multiemployer Insurance Program Deficit Threatens PBGC's Solvency

"The Projections Report makes it clear that there is absolutely no threat of a taxpayer bailout of the single-employer program. In fact, in the 5,000 scenarios simulated in PBGC's modeling, there were none in which PBGC ran out of money within the 10-year projection period. In contrast, despite the improving economy and strong asset returns in 2013, some already distressed multiemployer plans remain critically underfunded. Those plans could cause the agency's current multiemployer deficit of $8.3 billion to grow to $49.6 billion by 2023."

SEC to Finalize Money Market Fund Final Rule by May

"The regulator is once again crafting a plan that would force prime institutional MMFs to float the net asset value (NAV). However, the SEC is also considering complaints it has received from the MMF industry and is looking into exempting certain MMFs from having to float their share price. Specifically, the SEC is considering broadening its definition of retail MMFs, which are exempt from the floating NAV in the plan[.]"

CIEBA Presentation Before the PBGC Advisory Board on Defined Benefit Plans (PDF)

21 page PowerPoint Presentation. Excerpt: On December 8, 2009, CIEBA members testified before the PBGC Advisory Board on the state of defined benefit plan investments and the challenges they face in the current funding environment[.]

CIEBA Letter to Chairman Kennedy on Delaying PPA Implementation (PDF)

"The Committee on Investment of Employee Benefit Assets (CIEBA) urges you to support a delay in implementation of the new funding rules required by the Pension Protection Act (PPA) until final guidance is available."