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SEC Plans To Roll Back Obama-Era Mutual Fund Rules
Translation: Fund vendors, feel free to dump your speculative hard-to-value cr--p into vehicles that you then peddle to unwitting retail investors and pension funds. Because the financial sector must continue to privatize the profits, but socialize the risks and losses.
They have learned NOTHING from history. As many of us predicted would be the case.
I want to hear how the industry will try to explain how this is good for shareholders in any way, shape or form. Oh, wait, here it is:
The mutual-fund industry has panned what some analysts called the “bucketing” requirement, saying it requires them to make imperfect judgments about liquidity that could expose them to second-guessing by regulators and influential fund analysts such as Morningstar Inc.
“It is the industry’s single greatest concern with the rule,” said John Baker, a lawyer specializing in mutual funds at Stradley Ronon Stevens & Young LLP in Washington. “It’s very difficult to implement, it’s consuming a disproportionately large amount of resources, and there is real doubt as to how valuable this information will be to the SEC.”
The thing that's so laughable about this argument is that any fund shop investing in illiquid assets that isn't completely devoid of investment acumen would be assessing the liquidity of those assets anyway. They know internally what liquidity buckets those assets belong in. So why can't they disclose those buckets to shareholders and how will such disclosure be "consuming a disproportionately large amount of resources?" It's nonsense.
You said it better than I could. There are people out there who don't even know the difference between a stock and a bond. But let's permit these big outfits NOT to share information. Buncha crap.
You get one single, big, fat guess. Make sure all the wealth is concentrated in the hands of the (savvy) 1%, and screw the 99. With wealth already on your side, you can make the laws and regulations work toward that goal, too. The perfect scenario--- if you're in the oligarchy which is likewise already in charge. LB has already quoted from the disinformation campaign, above. And "Oceania has ALWAYS been at war with East Asia, eh?"
"... This post isn't about refugees, but Orwelianism. What's shown here is retroactive changing of history to conform to the new political consensus. It's doublethink, as people strive to change their own thinking. It's newspeek, as people try to change what others believe by changing the words used to express those ideas. It's also about the mainstream press, which has become part of the corrupt establishment, obviously violating every principle of journalism in order to exercise power." http://blog.erratasec.com/2016/02/weve-always-been-at-war-with-eastasia.html
Before leaping, it might be a good idea to understand what's being discussed here. (I'm just beginning to read the rule, so I speak from a fair amount of ignorance.)
ISTM that there are at least two different issues here. One concerns a 15% limit on the amount of illiquid securities a fund can purchase; another concerns how one classifies (tosses into buckets) those illiquid securities (once they're determined to be illiquid). The 15% limit does not appear to be on the table, the classification system of illiquid securities is.
We also are adopting a 15% limitation on funds’ purchases of illiquid investments, largely as proposed, but the definition of investments considered illiquid and subject to this 15% limit has been enhanced and substantially harmonized with the classification system we are adopting today.
I'm still trying to get my head wrapped around the concept that the same security could be classified differently with respect to liquidity by two funds, even managed by the same company (Final Rule, p. 100):
We recognize that, although we are providing a uniform classification framework, different funds may still classify the liquidity of similar investments differently, based on the facts and circumstances informing their analyses. This simply reflects the fact that different funds likely have different views on liquidity based on considerations such as their assessment of various market, trading, and investment-specific factors, and the size of their position in a particular investment. We acknowledge that liquidity can be difficult to estimate and that there is no agreed-upon measure of liquidity for all asset classes
Yes, that says "similar investments", not literally the same security, but SEC clarified in its FAQ (Q5): "Q: May different funds classify the same investment differently? A: Yes [then discusses the section of the Final Rule quoted above]"
Demonstrating that my little knowledge is a dangerous thing, here are the four categories (buckets) that the SEC Rule defines - note that three of them are slicing and dicing liquid assets; it's only the last bucket that is illiquid. This is roughly the opposite of what I was speculating above (that it was the illiquid securities that were sliced and diced).
From Final Rule, p. 90:
Highly Liquid - cash or convertible to cash within 3 business days
Moderately Liquid - convertible to cash in 3-7 calendar days under current market conditions
Less Liquid - can be sold within seven calendar days without moving market under current conditions, but settles in more than seven days
Illiquid - everything else
As an example of ambiguities in this scheme, how does one treat a line of credit?
The SEC writes (p. 85) that on the one hand, this could help funds meet redemption needs (thus it improves liquidity). On the other hand, in some cases this could be on balance detrimental to nonredeeming shareholders. They would be stuck with the carrying costs of the borrowed money. "Thus, we believe that funds should consider the likely overall benefits and risks in including such borrowing ..."
I'm still trying to get my head wrapped around the concept that the same security could be classified differently with respect to liquidity by two funds, even managed by the same company
Two things to consider:
1. Different funds have different amounts of the same security. A tiny fund investing in a microcap stock could have ample liquidity to trade it while a behemoth fund owning more than 5% of its outstanding shares won't be able to get out of the position without having significant market impact costs and liquidity problems. While there are differences fund families measure these differences internally.They should be able to come up with an estimate of what the liquidity of an individual portfolio is because they often stress test the portfolio and to actually manage it need to know how liquid everything is.
2. The more illiquid assets don't trade like stocks on an exchange and are often over the counter or by "appointment only." So a bond fund from one company that is well connected with bond dealers may have more liquidity for the same bond than another fund that owns it. Again, part of the compliance and internal risk control of any reasonably managed fund company would be to know very well what the available sources of liquidity are.
Yes, there will be different measurements for liquidity for different funds if the rule took affect. But so what as there are also different measures of fair value for illiquid securities at different funds. I say let fund companies make a good faith effort to disclose liquidity and let investors and professional fund analysts at Morningstar etc. evaluate that disclosure. Having differences might lead to more transparency and risk understanding than an ignorant consensus on liquidity would. If one fund is overestimating the liquidity for the same securities that other funds own, analysts can point that out and say they are understating their own liquidity risks.
Regulators engaged in jargon-speak. Am I in error to think that synthetic, derivative plays are part of this picture? I might want to suggest that some of the hair-brained synthetic bets are gambling, not investing, and ought to be disallowed completely, or regulated as gambling. But already, what I've read in this thread makes me want to vomit. Because nothing should be so complicated. Period.
Different funds have different amounts of the same security. A tiny fund investing in a microcap stock could have ample liquidity to trade it while a behemoth fund owning more than 5% of its outstanding shares won't be able to get out of the position without having significant market impact costs and liquidity problems.
If 'twere only like that.
Liquidity of a stock is progressive, much as income taxes are progressive. Rich man, poor man, the first $10K of income gets taxed at the same rate. The next $10K gets taxed at a higher rate, but the for both earners, and so on. Same for selling stocks. Big fund, little fund, the first 10K shares put on the auction block have the same liquidity, the next 10K shares are less liquid but the same for all sellers, and so on.
Simply averaging the liquidity of all shares held by a fund doesn't reflect reality. First of all, funds never need to sell all shares, unless they are shutting down. In that case, they can petition the SEC, as TFCIX did, to halt redemptions and liquidate their securities without holding a fire sale.
Secondly, even the Obama SEC recognized that: "evaluating “days-to-cash” was inherently biased against large funds" (p. 346 of Final Rule). So the SEC rule already allowed funds to consider liquidity impact "in sizes that the fund reasonably anticipates trading". Not full liquidation, and not under stress conditions.
Funds are loathe to disclose what they own, let alone what they are trading, not to mention what they anticipate trading. They don't plan on trading positions pro rata (same percentage of each holding to raise cash). They're not going to disclose their trading strategies to the SEC, not to mention the public at large (unless required by regulation - so far I haven't found anything compelling this level of disclosure, but I haven't read the rule in depth yet).
Yet by not disclosing this information, it would be easy for funds to claim higher liquidity than actually the case. They could pretend to have (hypothesize) a plan to sell more of their highly liquid assets and sell less of their illiquid securities. Unverifiable.
Then there's the matter of market conditions. You wrote about stress test data that funds have. But what the SEC wants is liquidity classification of securities under current market conditions. That's something different (and also gets us back to how lines of credit should be evaluated).
Once one opens the floodgates to allowing two funds to treat the same securities differently, it seems that metrics fly out the window, and fudging (analogous to window dressing) becomes the norm. Contrast that with the relatively simple partitioning of securities into liquid or illiquid in order to satisfy the existing 15% cap on buying illiquid securities.
Getting one's head wrapped around two funds being able to say that the same security has different degrees of liquidity means understanding not only how they could possibly put the security into two different buckets, but the consequences of that. Are the results meaningful? If fund X classifies security 1 as moderately liquid, and fund Y classifies security 2 as moderately liquid, are these securities really similar, when we don't know quite how the funds evaluate "current market conditions", or how flexible they are in altering their trading plans?
Once one opens the floodgates to allowing two funds to treat the same securities differently, it seems that metrics fly out the window, and fudging (analogous to window dressing) becomes the norm.
Regarding the SEC's interest, I do think they are concerned or were concerned before the recent shift in the agency's makeup about the selling of an entire position, not just the usual trading around the edges funds do on a day to day basis. Yes, funds will differ on how they estimate this liquidity, but having a window into their process for evaluating liquidity is useful info investors have a right to know in my opinion even when there are differences in interpretation. I think investors in Third Avenue Focused Credit would've benefited from knowing how illiquid that portfolio was from the beginning. I also understand that liquidity shifts over time. A large cap stock that becomes distressed and now a microcap will not be as liquid as it once was, but that change of liquidity should be evaluated, recorded and disclosed too on a periodic basis.
I also would add just because the SEC changed the final rule to accommodate larger funds--after I'm sure heavy pressure and lobbying from the fund industry--doesn't mean the final rule is in the best interests of fund shareholders as opposed to fund companies. The fact is, smaller funds have a liquidity advantage over larger ones and that advantage should be disclosed to shareholders. In fact, I would say the reason Mutual Fund Observer exists is in part because of that small undiscovered fund advantage.
I didn't address your comment about the problems in valuing illiquid securities because I felt that while that was related, it did not directly address the matter of degrees of liquidity, and disclosure thereof.
Likewise, while the SEC may be (almost surely is) interested in full liquidation costs and risks, that isn't the focus of the rule or what is being opened for reconsideration.
Would investors in TFCIX really have cared whether some of the securities might have taken seven days instead of three days to convert to cash (i.e. which of the three buckets for liquid holdings the securities fell into)? Or rather would they have cared how much of the fund was hard to sell at a reasonable price (illiquid)? Because that info was already disclosed (one can argue that it should have been more accessible, though).
The fund disclosed, for example, that its so-called Level 3 assets, or securities that are hard to value and trade, were 20% of assets at the end of July [2015]. That was higher than at any other US junk bond fund with at least $500 million in assets, according to a Reuters analysis of fund disclosures. And the fund had 76% of its portfolio exposed to very low-rated "CCC+" rated securities and below, compared with a median level of 22% among similar junk funds, according to analysts at Citigroup
It may be debatable whether Schwab lied to investors about the fund [Schwab had marketed the fund as a MMF alternative]. But it is clear that it misled them about a crucial aspect of the fund’s investments. ...
The S.E.C. states that in mid-2007, only 6 percent of the fund’s assets matured within six months. ... That maturity risk would have been obvious to anyone who understands bonds. ... But ... the 2007 annual report ... said that on Aug. 31 of that year, more than 60 percent of the fund’s assets had maturities of six months or less. [And the report's glossary defined maturity] to mean just what it really means: “The date a debt security is scheduled to be ‘retired’ and its principal returned to the bondholder.”
[However, at the top of the list of fund assets, it said that for adjustable rate securities, maturity meant] “the next interest rate change date.”
For whatever reasons, most investors don't make use of information already available. It's partly due to accessibility, and partly because people simply choose to ignore what they do have access to. (Keep in mind that the SEC created stripped down summary prospectuses because people weren't reading the information that was already placed in their hands, literally.)
Making information about illiquid holdings easier to find would be great. Slicing and dicing degrees of liquidity (0-3 days, 3-7 days, 7 days but later settlement) not so much. Especially if that fine granularity is created using such subjective (and undisclosed) factors as to render it meaningless.
I prefer the risk of one or two examples of intentionally fudged or incompetently assessed numbers over a completely inaccurate consensus or a black box of ignorance. If you think about the case of valuing illiquid Uber private equity for instance, one approach would be to merely maintain the purchase price of the security on the books no matter what market conditions are. This was not uncommon in the past. Another approach would be to take the latest sale's price of the security the last time it traded even though that price is stale and could be months old and much could've changed in the interim. Managers instead use a fair value system in which they generally hire an independent third party to assess the value of the illiquid asset based on current market conditions. When they screw that assessment up or intentionally fudge the assessment, there are legal ramifications that often get resolved in court. But without any public disclosure of the assessed price or with instead public disclosure of an unrealistic stale consensus price, there is much more limited liability and less of a paper trail for lawyers and prosecutors to use in pursuing the parties guilty of fraud or incompetence.
Yes, you could argue that the average retail investor will never look at liquidity disclosures. Indeed, the average retail investor cares only about performance and now more recently fees. But professional analysts could use the data at places like Morningstar to come up with liquidity ratings for funds. The SEC can certainly used the data for its investigations. And institutional investors and investigative journalists can use the data as well. Financial advisers worth their salt most certainly could use the data so even if their clients don't care about it, they should and alert their clients if there is a problem.
"But without any public disclosure of the assessed price or public disclosure of an unrealistic stale consensus price, there is much more limited liability and less of a paper trail for lawyers and prosecutors to use in pursuing the parties guilty of fraud or incompetence."
The amount of liability (losses due to mispricing) does not depend on disclosure. What is most affected by lack of disclosure is the probability of being caught and held accountable. The paper trail will exist with or without public disclosure - funds must be able to provide that for SEC compliance inspections. That data should be subject to discovery.
The SEC staff conducts compliance examinations of ... investment companies ... to determine whether these firms are in compliance with the federal securities laws and rules ...
Many high yield municipal bond funds invest in securities that trade in the secondary market on an infrequent basis or never trade in the secondary market. ... Further, liquidity determinations for a high yield municipal bond fund are critical to ensure that the fund is able to redeem fund shares within seven days, as required under the Investment Company Act. ...
[E]xaminers: analyzed the credit quality of portfolio holdings; reviewed illiquidity levels as determined by fund management; compared sales prices to prior day valuations; compared bond valuations provided by pricing services to market transaction data; ...
[E]xaminers noted the following: ... Disclosure. High yield funds often did not disclose the increased risk with respect to liquidity and valuation, as required. For example, examiners commented in situations where the percentage of illiquid securities held by a fund dramatically increased and the fund did not disclose: that a dramatic increase in the percentage of the fund invested in illiquid securities occurred and the risks associated with such an increase; what effect, if any, the increase may have on the fund’s ability to redeem investor shares in a timely manner consistent with the federal securities laws; and what steps, if any, the fund may take to dispose of some of the illiquid securities to bring the percentage within a range appropriate to the circumstances.
One takeaway - even the (relatively simple to compute) illiquidity percentage was often not disclosed, even though such disclose is already required.
Every once in awhile there's merit in the position that the government should enforce existing regulations before adding new ones. What's the point in requiring funds to disclose what at best are noisy estimates of liquidity slices (3 day, 7 day, etc.) - estimates that would merely enhance the value of illiquidity percentage data - when the latter aren't being properly disclosed?
As to astute financial advisers making use of this "additional" information: how many advisers are making use of the new disclosure of (mark-to-market) NAV values for prime MMFs?
Comments
They have learned NOTHING from history. As many of us predicted would be the case.
So much #winning!
Here's the full article, but with paywall:https://wsj.com/articles/regulators-to-pull-back-on-obama-era-mutual-fund-rules-1519338039
"... This post isn't about refugees, but Orwelianism. What's shown here is retroactive changing of history to conform to the new political consensus. It's doublethink, as people strive to change their own thinking. It's newspeek, as people try to change what others believe by changing the words used to express those ideas. It's also about the mainstream press, which has become part of the corrupt establishment, obviously violating every principle of journalism in order to exercise power."
http://blog.erratasec.com/2016/02/weve-always-been-at-war-with-eastasia.html
ISTM that there are at least two different issues here. One concerns a 15% limit on the amount of illiquid securities a fund can purchase; another concerns how one classifies (tosses into buckets) those illiquid securities (once they're determined to be illiquid). The 15% limit does not appear to be on the table, the classification system of illiquid securities is.
From the Final Rule (p. 10 of 459!): I'm still trying to get my head wrapped around the concept that the same security could be classified differently with respect to liquidity by two funds, even managed by the same company (Final Rule, p. 100):Yes, that says "similar investments", not literally the same security, but SEC clarified in its FAQ (Q5): "Q: May different funds classify the same investment differently? A: Yes [then discusses the section of the Final Rule quoted above]"
Another report: http://www.thinkadvisor.com/2018/02/22/sec-extends-liquidity-rule-deadline-for-open-end-f?slreturn=1519403206
From Final Rule, p. 90:
- Highly Liquid - cash or convertible to cash within 3 business days
- Moderately Liquid - convertible to cash in 3-7 calendar days under current market conditions
- Less Liquid - can be sold within seven calendar days without moving market under current conditions, but settles in more than seven days
- Illiquid - everything else
As an example of ambiguities in this scheme, how does one treat a line of credit?The SEC writes (p. 85) that on the one hand, this could help funds meet redemption needs (thus it improves liquidity). On the other hand, in some cases this could be on balance detrimental to nonredeeming shareholders. They would be stuck with the carrying costs of the borrowed money. "Thus, we believe that funds should consider the likely overall benefits and risks in including such borrowing ..."
1. Different funds have different amounts of the same security. A tiny fund investing in a microcap stock could have ample liquidity to trade it while a behemoth fund owning more than 5% of its outstanding shares won't be able to get out of the position without having significant market impact costs and liquidity problems. While there are differences fund families measure these differences internally.They should be able to come up with an estimate of what the liquidity of an individual portfolio is because they often stress test the portfolio and to actually manage it need to know how liquid everything is.
2. The more illiquid assets don't trade like stocks on an exchange and are often over the counter or by "appointment only." So a bond fund from one company that is well connected with bond dealers may have more liquidity for the same bond than another fund that owns it. Again, part of the compliance and internal risk control of any reasonably managed fund company would be to know very well what the available sources of liquidity are.
Yes, there will be different measurements for liquidity for different funds if the rule took affect. But so what as there are also different measures of fair value for illiquid securities at different funds. I say let fund companies make a good faith effort to disclose liquidity and let investors and professional fund analysts at Morningstar etc. evaluate that disclosure. Having differences might lead to more transparency and risk understanding than an ignorant consensus on liquidity would. If one fund is overestimating the liquidity for the same securities that other funds own, analysts can point that out and say they are understating their own liquidity risks.
Liquidity of a stock is progressive, much as income taxes are progressive. Rich man, poor man, the first $10K of income gets taxed at the same rate. The next $10K gets taxed at a higher rate, but the for both earners, and so on. Same for selling stocks. Big fund, little fund, the first 10K shares put on the auction block have the same liquidity, the next 10K shares are less liquid but the same for all sellers, and so on.
Simply averaging the liquidity of all shares held by a fund doesn't reflect reality. First of all, funds never need to sell all shares, unless they are shutting down. In that case, they can petition the SEC, as TFCIX did, to halt redemptions and liquidate their securities without holding a fire sale.
Secondly, even the Obama SEC recognized that: "evaluating “days-to-cash” was inherently biased against large funds" (p. 346 of Final Rule). So the SEC rule already allowed funds to consider liquidity impact "in sizes that the fund reasonably anticipates trading". Not full liquidation, and not under stress conditions.
Funds are loathe to disclose what they own, let alone what they are trading, not to mention what they anticipate trading. They don't plan on trading positions pro rata (same percentage of each holding to raise cash). They're not going to disclose their trading strategies to the SEC, not to mention the public at large (unless required by regulation - so far I haven't found anything compelling this level of disclosure, but I haven't read the rule in depth yet).
Yet by not disclosing this information, it would be easy for funds to claim higher liquidity than actually the case. They could pretend to have (hypothesize) a plan to sell more of their highly liquid assets and sell less of their illiquid securities. Unverifiable.
Then there's the matter of market conditions. You wrote about stress test data that funds have. But what the SEC wants is liquidity classification of securities under current market conditions. That's something different (and also gets us back to how lines of credit should be evaluated).
Once one opens the floodgates to allowing two funds to treat the same securities differently, it seems that metrics fly out the window, and fudging (analogous to window dressing) becomes the norm. Contrast that with the relatively simple partitioning of securities into liquid or illiquid in order to satisfy the existing 15% cap on buying illiquid securities.
Getting one's head wrapped around two funds being able to say that the same security has different degrees of liquidity means understanding not only how they could possibly put the security into two different buckets, but the consequences of that. Are the results meaningful? If fund X classifies security 1 as moderately liquid, and fund Y classifies security 2 as moderately liquid, are these securities really similar, when we don't know quite how the funds evaluate "current market conditions", or how flexible they are in altering their trading plans?
https://wsj.com/articles/mutual-funds-mark-down-uber-investments-by-up-to-15-1503443267
Regarding the SEC's interest, I do think they are concerned or were concerned before the recent shift in the agency's makeup about the selling of an entire position, not just the usual trading around the edges funds do on a day to day basis. Yes, funds will differ on how they estimate this liquidity, but having a window into their process for evaluating liquidity is useful info investors have a right to know in my opinion even when there are differences in interpretation. I think investors in Third Avenue Focused Credit would've benefited from knowing how illiquid that portfolio was from the beginning. I also understand that liquidity shifts over time. A large cap stock that becomes distressed and now a microcap will not be as liquid as it once was, but that change of liquidity should be evaluated, recorded and disclosed too on a periodic basis.
I also would add just because the SEC changed the final rule to accommodate larger funds--after I'm sure heavy pressure and lobbying from the fund industry--doesn't mean the final rule is in the best interests of fund shareholders as opposed to fund companies. The fact is, smaller funds have a liquidity advantage over larger ones and that advantage should be disclosed to shareholders. In fact, I would say the reason Mutual Fund Observer exists is in part because of that small undiscovered fund advantage.
Also, I didn't want to go down that path, otherwise I'd have started writing about why I will never invest in Heartland funds. Mispricing, including fraudulent mispricing has been going on for decades, see, e.g.
https://www.plansponsor.com/sec-charges-firm-mispriced-two-junk-bond-funds/
Likewise, while the SEC may be (almost surely is) interested in full liquidation costs and risks, that isn't the focus of the rule or what is being opened for reconsideration.
Would investors in TFCIX really have cared whether some of the securities might have taken seven days instead of three days to convert to cash (i.e. which of the three buckets for liquid holdings the securities fell into)? Or rather would they have cared how much of the fund was hard to sell at a reasonable price (illiquid)? Because that info was already disclosed (one can argue that it should have been more accessible, though).http://www.businessinsider.com/r-hidden-in-plain-sight-big-risks-at-failed-third-avenue-fund-were-clear-to-some-2015-12
Contrast that with Schwab's Yield Plus fund. http://www.nytimes.com/2011/01/14/business/14norris.html
For whatever reasons, most investors don't make use of information already available. It's partly due to accessibility, and partly because people simply choose to ignore what they do have access to. (Keep in mind that the SEC created stripped down summary prospectuses because people weren't reading the information that was already placed in their hands, literally.)
Making information about illiquid holdings easier to find would be great. Slicing and dicing degrees of liquidity (0-3 days, 3-7 days, 7 days but later settlement) not so much. Especially if that fine granularity is created using such subjective (and undisclosed) factors as to render it meaningless.
Yes, you could argue that the average retail investor will never look at liquidity disclosures. Indeed, the average retail investor cares only about performance and now more recently fees. But professional analysts could use the data at places like Morningstar to come up with liquidity ratings for funds. The SEC can certainly used the data for its investigations. And institutional investors and investigative journalists can use the data as well. Financial advisers worth their salt most certainly could use the data so even if their clients don't care about it, they should and alert their clients if there is a problem.
The amount of liability (losses due to mispricing) does not depend on disclosure. What is most affected by lack of disclosure is the probability of being caught and held accountable. The paper trail will exist with or without public disclosure - funds must be able to provide that for SEC compliance inspections. That data should be subject to discovery.
For example, here's an SEC compliance alert from July 2008: One takeaway - even the (relatively simple to compute) illiquidity percentage was often not disclosed, even though such disclose is already required.
Every once in awhile there's merit in the position that the government should enforce existing regulations before adding new ones. What's the point in requiring funds to disclose what at best are noisy estimates of liquidity slices (3 day, 7 day, etc.) - estimates that would merely enhance the value of illiquidity percentage data - when the latter aren't being properly disclosed?
As to astute financial advisers making use of this "additional" information: how many advisers are making use of the new disclosure of (mark-to-market) NAV values for prime MMFs?