The FSOC’s creation is a mandate by the Dodd Frank Act. After the SEC stopped pursuing additional regulations for the mutual fund industry last week, there seemed to be two paths the FSOC could take. Neither was without some type of drawback.
 
One of those options was to designate money market fund companies and individual funds as systematically significant. This would have effectively moved money fund oversight from the SEC to the Federal Reserve.
 
The other option was to state that activity in general by money funds posed a risk to the financial system. This approach would trigger other steps laid out by Dodd Frank that would lead oversight back to the SEC.
 
But a third option has been identified that may overcome the drawbacks of the other two. There’s a section of Dodd Frank called Title VIII that focuses on the inner workings of the financial system. These inner workings involve activities like processing transactions and organizing financial payments.
 
Utilizing this third option would involve a two-step process. First, an activity or feature of money funds would have to be titled as a systematic utility function. Second, reforms would be proposed to support that function.
 
For example, the stable net asset value of money funds could be declared as systematic by the FSOC. This would open the door to the requirement that funds hold capital.
 
This would keep oversight of the funds in the hands of the SEC. It would also avoid some type of stalemate on money fund regulation. With this option, however, the money fund industry could make the claim that money funds are not part of the payment functions of the financial system.

 

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With classes approved for over a decade by the CFP Board, IWI, and NASBA, Advisors4Advisors CE classes are an optimal knowledge stream for CFP®, CIMA®, CPA, CPA/PFS®, CFA®, and other practitioners. It's not a grab bag of speakers willing to sponsor CE content. Nor is it a one-man CE course. It's a group of subject matter experts with amazing communication skills and a history of thought leadership that, together, give advisors a well-rounded knowledge system for running a professional practice ethically and intelligently.

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I’ve subscribed to A4A since its inception, and always find it intellectually stimulating and on point. It’s one of the few CE solutions out there that doesn’t waste my time by pushing product or talking down to me.

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Pete Deacon, CPA, CFP®
A4A has had a profound effect on my business. Since 2009, I’ve relied on the consistent messaging and updates to run my business successfully. Being able to present the information from Bob, Fritz, and Craig's ongoing CE webinars has been a significant benefit.

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I’ve been attending A4A many years because the CE classes are outstanding, and my time is valuable. Though I have over 35 years of experience, I’m always learning something new on A4A. I attend fewer conferences now because the CE is generally not advanced. If you want to learn from the best, in a faster, easier, and less expensive way, I highly recommend A4A.

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