Impact of SEC Rule Changes for Money Market Funds Regulatory Update

Over the past year, the SEC has been phasing in regulatory changes for money market funds resulting from adopted amendments to Rule 2a-7. These amendments were passed on July 12, 2023, in response to the stress that money market funds faced at the start of the pandemic in March 2020 when investors rapidly pulled more than $130 billion dollars from money market funds. As a result, the Treasury and Federal Reserve had to step in to provide emergency liquidity facilities to shore up the short-term funding market. The changes primarily focus on institutional prime and tax-exempt money market funds, which have historically been more susceptible to investor runs.

This regulatory update summarizes these changes as well as which fund types are impacted.

The Growing Popularity of Continuation Funds

Historically, the private equity secondary market has been used by limited partners (“LPs”) to sell exposures at the end of their lives and as such contained only tail-end exposures. Selling these lingering exposures to private equity funds allowed LPs to clean up their balance sheets and fueled the growth of secondary private equity funds within the broader private equity space. As the market evolved, however, higher-quality assets began transacting as investors started to use secondary markets as a useful portfolio management tool. More recently, general partners (“GPs”) have come to occupy an increasing percentage of the overall market. In 2023, about $110 billion in volume traded in private equity secondaries, with about 50% of the total transaction activity represented by GP-led transactions.

In this newsletter, we provide an overview of continuation funds, including their growth, structure, transaction requirements, and considerations for investors.

Mind the Gap

Any ride on the London Tube reminds riders to mind the gap: Beware the space between train car and platform as you board and depart the train. A recent trip to London brought this phrase back to me and it seemed like a perfect description of how to look at financial markets this year, with the “gap” serving as the difference between expectations and reality, most particularly in terms of interest rate cuts.

In our market preview, we identified the Fed pivot as a primary driver of financial markets this year, most especially how expectations of cuts would line up with actual Fed policy. Going into the year, the market had priced in at least five cuts, which helped fuel a furious fourth quarter rally and investor optimism for 2024. One quarter in, however, those expectations have been turned on their head. Hotter than expected inflation and jobs reports in March have created a “higher for longer” narrative with the market expecting no more than two cuts during the second half of the year. Some economists have taken an even more bearish stance, suggesting there will not be any cuts. Overall, rates rose across the curve during the quarter as current U.S. debt levels sustained the long end of the curve while the short end was relatively unmoved.

Intuitively, many investors would expect such a big change in rate expectations to weigh heavily on markets, both equities and bonds. In that sense, equity performance was surprising during the first quarter, as the upward trend from 2023 continued. Predictably, bonds suffered as rates rose, but below investment grade sectors were profitable. To be fair, though, it should be noted that equities have endured a difficult start to this month, down 4.6% through April 22 as the higher for longer narrative has gained momentum.¹

Going forward, what should we watch for from asset classes as we venture into a market environment that looks much different than what we were expecting only three months ago?

2024 Market Preview Video

This video is a recording of a live webinar held January 25 by Marquette’s research team analyzing 2023 across the economy and various asset classes as well as what trends and themes we’ll be monitoring in the year ahead.

Our quarterly Market Insights series examines the primary asset classes we cover for clients including the U.S. economy, fixed income, U.S. and non-U.S. equities, hedge funds, real assets, and private markets, with commentary by our research analysts and directors.

Featuring:
Greg Leonberger, FSA, EA, MAAA, FCA, Director of Research, Managing Partner
Frank Valle, CFA, CAIA, Senior Research Analyst
Catherine Hillier, Research Analyst
David Hernandez, CFA, Director of Traditional Manager Search
Evan Frazier, CFA, CAIA, Senior Research Analyst
Griffin Gildea, Associate Research Analyst
Hayley McCollum, Research Analyst
Chad Sheaffer, CFA, CAIA, Senior Research Analyst

 

Sign up for research alerts to be invited to future webinars and notified when we publish new videos. If you have any questions, please send us an email.

Great Expectations

After ending 2023 with a steep market rally, 2024 began on a more muted note, with Fed-pivot exuberance giving way to the details of execution. Of the many opportunities and risks facing markets this year, one of the most scrutinized will likely be how the Fed’s interest rate cuts compare to market expectations.

This newsletter analyzes current expectations for interest rate movements this year and potential scenarios that could influence the Fed’s policy decisions.

Defined Contribution Plan Legislative Update – 1Q 2024

This legislative update covers proposed regulation by the Department of Labor defining “investment fiduciary,” outlines SECURE Act 2.0’s optional provision regarding student loan repayments, analyzes an increasing trend of private real estate investments within defined contribution plans, summarizes new guidance from CFA Institute defining responsible investment terminology, and reviews 2024 contribution limits from the IRS.

Ryan P. Tracy Speaking at Titan Investors Denver Private Active Exchange 7/24

On Wednesday, July 24, Ryan P. Tracy, CFP® will be speaking at the Denver Private Active Exchange hosted by Titan Investors.

Ryan will be moderating the Private Markets Panel at the event, which will bring together investment staff from Denver’s leading private wealth asset allocators with a focus on networking and high level strategic insights from speakers and breakout sessions.

Titan Investors is a boutique consulting firm that connects asset allocators and investment managers to share ideas, build relationships, and drive business in a focused environment. For more information, visit their website.

We’re Not So Different, High Yield Bonds and Leveraged Loans

Late last year we authored an article detailing the growing differences between the high yield and leveraged loan markets, particularly the overall quality in the high yield market versus that of leveraged loans. Today, some of those most pronounced differences appear to be abating, which should translate to a more convergent outlook for the two markets as it relates to security, structure, recovery, covenants, and ultimately, performance. With the Fed poised to begin cutting rates in 2024, we felt it was important to address these emerging trends before the start of the new year.

3Q 2023 Market Insights Video

This video is a recording of a live webinar held on October 26 by Marquette’s research team, featuring in-depth analysis of the third quarter and themes we’ll be monitoring for the remainder of the year. Our Market Insights series examines the primary asset classes we cover for clients including the U.S. economy, fixed income, U.S. and non-U.S. equities, hedge funds, real estate, infrastructure, private equity, and private credit, with presentations by our research analysts and directors.

Featuring:
Greg Leonberger, FSA, EA, MAAA, FCA, Director of Research, Managing Partner
Evan Frazier, CFA, CAIA, Senior Research Analyst
Frank Valle, CFA, CAIA, Senior Research Analyst
Catherine Hillier, Research Analyst
David Hernandez, CFA, Associate Director
Chad Sheaffer, CFA, CAIA, Senior Research Analyst
Griffin Gildea, Research Associate
Hayley McCollum, Research Analyst
Brett Graffy, CAIA, Associate Director

 

Sign up for research alerts to be invited to future webinars and notified when we publish new videos.
For more information, questions, or feedback, please send us an email.

2023 Investment Symposium

Watch the flash talks from Marquette’s 2023 Investment Symposium livestream on September 15 in the player below — use the upper-right list icon to access a specific presentation.

 

Please feel free to reach out to any of the presenters should you have any questions.

 

The opinions expressed herein are those of Marquette Associates, Inc. (“Marquette”), and are subject to change without notice. This material is not financial advice or an offer to purchase or sell any product. Marquette reserves the right to modify its current investment strategies and techniques based on changing market dynamics or client needs. Past performance is not indicative of future results. For full disclosure information, please refer to the end of each presentation. Marquette is an independent investment adviser registered under the Investment Advisers Act of 1940, as amended. Registration does not imply a certain level of skill or training. More information about Marquette including our investment strategies, fees and objectives can be found in our ADV Part 2, which is available upon request.