FYI: The Securities and Exchange Commission had originally lumped ETFs in with mutual funds last year when proposing the rules, which try to make sure that firms can more easily sell assets to meet demands from investors who want to cash out during market downturns. ETF providers had pushed back on the inclusion, with BlackRock Inc., the world’s largest asset manager, arguing that the structure of many ETFs makes them more liquid than mutual funds. Vanguard Group is also one of the biggest providers of ETFs
Regards,
Ted
http://www.bloomberg.com/news/articles/2016-10-13/blackrock-poised-for-etf-regulatory-win-in-fund-liquidity-rule
Comments
Perhaps the bigger item got buried - funds are now allowed to use swing pricing in times of stress (essentially impose redemption fees by passing through the cost of selling underlying securities to meet redemptions).
Here's that SEC final rule (198 pages):
https://www.sec.gov/rules/final/2016/33-10234.pdf
There's got to be more on the liquidity rule than is being reported, especially regarding Vanguard. Here's the SEC final rule (459 pages): https://www.sec.gov/rules/final/2016/33-10233.pdf
First, because ETFs would seem to have a liquidity problem similar to open end funds. When there is large selling pressure, authorized participants (AP) are supposed to swoop in, buy up the ETF shares being sold on the open market, and then sell the underlying securities at a profit. So even though the fund itself doesn't sell assets, the APs are expected to. if they don't (because of illiquidity) the ETF price could go into free fall.
Second, the report says that this rule applies to funds that provide daily portfolio information. What sort of info? All ETFs provide indicative NAV and portfolio composition files, but they are not required to provide daily portfolios. In fact, Vanguard discloses its ETF portfolios only monthly.
Third, Vanguard's ETFs are unique in that they are simply shares of an open end fund portfolio. Is this a back door way for Vanguard to avoid meeting liquidity requirements on its open end funds?
P.S. No, I have not read the 650+ pages from the SEC.
Other takes:
http://www.reuters.com/article/us-sec-funds-idUSKCN12D21R
http://www.thinkadvisor.com/2016/10/13/sec-imposes-sweeping-liquidity-rules-for-mutual-fu
An observation. Kinda like, if a too-big-to-fail or other event sets the wheels spinning again; and some folks (like we folks here) want to leave the party early or during a melt; this becomes a type of "Hotel California", you know: "You can check in any time you want, but you can never leave."
One may suppose if enough folks had gone below decks to fill the gash in the hull of the Titanic, perhaps the vessel would have stayed afloat longer and more people would have survived.
Well, anyway; just a sideways view of what you noted from an "agency" of the people.
Take care,
Catch
http://www.alfi.lu/sites/alfi.lu/files/ALFI-Swing-Pricing-Survey-2015-FINAL.pdf