Excerpts from letters to the Federal Reserve Board and other federal banking regulators concerning the growing investor perception that banking organizations are effectively guaranteeing their affiliated money market funds. The letters show how bank regulatory policies are fostering this...

This Article argues that the Securities and Exchange Commission's first and most significant response to the economic crisis increases rather than decreases the likelihood of future failures in money market funds and the broader capital markets. In newly promulgated regulations addressing the...

The events following Lehman's failure in 2008 and the current turmoil emanating from Europe highlight the structural vulnerabilities of short-term credit markets and the role of central banks as back-stop liquidity providers to financial markets. The Federal Reserve's response to financial...

The merit of further reform of money market funds by the SEC hinges on the extent to which runs on prime funds pose an investor-protection problem. Reformers assume that the many runs on prime funds in 2008 reflected rational inter-shareholder opportunism, but there is no evidence that retail...

Although most money market mutual funds hold floating rate instruments to some extent, funds rarely identify the market rate that any individual holding floats on. This makes it difficult to determine (directly) a fund's exposure to Libor manipulation. Effective Libor exposure possibly is...

This paper discusses reasons why money market funds do not pose a systemic risk to the United States banking system, highlighting regulatory differences from banking organizations that make MMFs more liquid, diversified, safe, and efficient than banks. This paper is based on the author's oral...