A good oped in Bloomberg's "Business Class" series tackles money market funds. (I signed it along with the rest of the Squam Lake group, but I can't take credit for much of the writing.)
There was a run in money market funds. We have to do something about this.
Money market funds are a bank. Their liabilities are fixed value, first-come first-serve, just like deposits. Their assets are longer term, and less liquid. This fact puts them at risk for a run. The essence of stopping future financial crises is stopping runs.
One way to stop a run is for the government guarantee all the liabilities. That stops the run, but gives horrible incentives to the fund managers, so now you need regulation. This is what we did with banks and what the industry seems to want for money market funds. Watch for what you ask for, you just might get it.
The Squam Lake group, and others thinking about these issues, note two other eminently sensible possibilities.
First, money market funds can trade at net asset value, just like equity mutual funds or exchange traded funds. (The small difference between those doesn't matter here.) Now there is much less incentive to run. The situation that happened with the Reserve Fund in the financial crisis, that everyone sees net asset value less than a dollar per share and knows it's time to run, cannot happen.
This seems like the simplest fix. In the modern world, liquidity need not mean fixed value.
Alas, as the more knowledgeable Squam members informed me, this conceptually simple resolution to the problem causes accounting and tax problems. Money funds are used as money. If I have to pay you $1,000, it's easy to say "sell 1,000 shares and send the proceeds." It's much harder, technically, to say "sell $1,000 worth of shares and send the proceeds."
The tax issue is that if every transaction takes place at a different market value, then you have to track capital gains and losses on a huge number of transactions.
Say I, well, for a few hundred billion dollars we can surely fix these accounting and tax law problems (like get rid of capital gains tax!). Why accept that one bad regulation must beget another? But critics are right that this does spread the difficulty of making a change.
Second, money market funds can include capital just as banks do. If there is an equity tranche holding even a few percent of value, then money funds can promise $1 per share and always have net asset value above that. Banks have equity tranches. So can money funds. If we're going to maintain $1 per share, this seems like a no brainer, and basically what the Oped calls for. The objections, like most objections to higher capital for banks, basically don't understand the Modigliani Miller theorem.
That said, money market funds are a lot simpler than banks, and fixing the regulatory system is a bit less crucial in my view.
The chance of a systemic run is lower for money market funds. The danger in a systemic run is that bank A is found to be insolvent; people don't know what bank B's assets are, so they run just to be sure. That's not what happened at the Reserve Fund: People knew it held a lot of Lehman paper, and knew it was insolvent. People can see what assets the other money market funds had, and quickly verify if the did or did not hold Lehman paper.
The transparency of money market funds -- the fact that we know the net asset values pretty well and the composition of assets -- makes the chances of a "multiple equilibrium" run or a "systemic" run a lot less than that of banks.
Still, there is no reason to put up with runs at all, or to provide a blanket government guarantee, when fairly simple changes to the contracts can fix the problems.
Facilitating NAV trading or an equity buffer is important for another reason -- to expand money market funds and let them take on more risk.
The SEC has already started the "regulate" part of the traditional model by forcing money market funds to shorten the maturity of their assets. Great, but as forcing institutions to buy "AAA" debt subsidized the artificial creation of "AAA" assets, forcing funds to hold "short term" debt subsidizes creation of short-term liabilities. And short term debt anywhere is the poison in the well that causes crises. It encourages banks and other issuers to finance themselves with a lot of short-term debt, exactly the opposite of what we want.
You can move risk around, you can't eliminate it. Keeping the risk in the fairly transparent money market funds with a solid equity tranche rather than in the bowels of horribly complex too big to fail banks seems like a good idea.