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May 8, 2020

Better Markets’ Comment Letter on Regulatory Capital Rule Money Market Mutual Fund Liquidity Facility

The Money Market Fund Liquidity Facility (MMF) is a reasonable measure that is likely to encourage bank participation in an emergency lending facility that has recently become necessary to alleviate the extraordinary pressures facing money market mutual funds as a result of the COVID-19 pandemic.  A foreseeable, predictable, and indeed predicted run has materialized in MMF markets, causing liquidity pressures, fire sales, downward price spirals, and other contagions.  We submitted this comment letter not to critique the rule but to highlight once again the continuing vulnerability of MMFs to financial crises and the indefensible failure of the appropriate regulators. Read our full comments here or by clicking the button below.

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