VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

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justinvest
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VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

The VMMXX-Vanguard Prime Money Market as of 11/30/2016 is 55% invested in Foreign/Yankee debt instruments. At the same time I have noticed that the last-7-day SEC annualized yield is 0.73%, which is significantly more than, say, a year ago.

This brings up the question, how safe and liquid are these Yankee/Foreign instruments? One can look up all the specific recent holdings (again 11/30/2016) via a link from Vanguard website, but here are explicit links just for reference:

https://www.sec.gov/cgi-bin/browse-edga ... cd=filings
https://www.sec.gov/Archives/edgar/data ... ry_doc.xml

I'm a long-time investor in VMMXX, but I am starting to wonder whether it is getting to become more risky with all the bank stress in Europe and so on. I have not tallied up the holdings data in gory detail, but, for example, Dutch bank subsidiary ABN AMRO FUNDING USA LLC is one of the significant borrowers from VMMXX.

So the question remains, is VMMXX ever likely to break the buck (trade below 1.00 NAV) due to this 55% exposure? We all know what happens when there is a financial crisis like in 2008--pretty much everything goes to heck at the same time, and there may be no safe havens except perhaps VMFXX, which as of yesterday also yields 0.44% which is quite decent compared with getting 4-week T-Bills at 0.45%, albeit VMFXX is slightly less liquid given that the mix of durations is a bit longer.

A presumably still safer alternative would be to construct a FDIC-insured CD ladder, but with today's CD offering it is hard to get over about 0.65% even for a 3-month CD among the Vanguard "brokered CD" offerings. While the CD should be safe as to return of principal (as long as you stay below 250k/bank), the liquidation timeframe of a brokered CD going into FDIC receivership may be 60-90days, according to what I have read.

In summary, VMMXX at 0.73% seems the best MM alternative as far as rate, but how risky and/or illiquid can those yankee/foreign instruments get? I'm not looking for investment chestnut responses of the type "higher rate always means higher risk". I know that already. But if anyone has better insight about how VMMXX might fare in a crisis, based on current holdings, that would be appreciated, In any case I hope my little analysis may be useful to others.
Last edited by justinvest on Fri Dec 30, 2016 5:21 pm, edited 2 times in total.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by LadyGeek »

Welcome! I want to clarify that "Yankee obligations" is a standard term. From: Investing Answers
Yankee bonds are bonds issued in the U.S. bond market by a foreign entity, and they are denominated in U.S. dollars. Governments, companies, and other entities issue Yankee bonds.
From Vanguard's prospectus:Prospectus (SEC filing)
The Fund may also invest in Eurodollar and Yankee obligations, which include certificates of deposit issued in U.S. dollars by foreign banks and foreign branches of U.S. banks. Eurodollar and Yankee obligations have the same risks as U.S. money market instruments, such as income risk and credit risk.

Additional risks of Eurodollar and Yankee obligations include the chance that a foreign government will not let U.S. dollar-denominated assets leave the country, the chance that the banks that issue Eurodollar obligations will not be subject to the same regulations as U.S. banks, and the chance that adverse political or economic developments will affect investments in a foreign country.

Before the Fund’s advisor selects a Eurodollar or Yankee obligation, however, any foreign issuer undergoes the same credit-quality analysis and tests of financial strength as those for the issuers of domestic securities.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

Btw, if this thread is better suited for the "theory, news & general" category than the "personal" category, I will not complain if it gets moved by the admins.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by patrick »

I do not think this is a big risk. However, I would still avoid money market funds because bank deposits can pay more interest. Redneck Bank pays me 1.25% on the money market deposit account, and unlike the money market fund they have FDIC insurance, and best of all a debit card with a picture of a horse on it!
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by LadyGeek »

justinvest wrote:Btw, if this thread is better suited for the "theory, news & general" category than the "personal" category, I will not complain if it gets moved by the admins.
That would be me. :) This thread is now in the Investing - Theory, News & General forum (general question).
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

patrick wrote:I do not think this is a big risk. However, I would still avoid money market funds because bank deposits can pay more interest. Redneck Bank pays me 1.25% on the money market deposit account, and unlike the money market fund they have FDIC insurance, and best of all a debit card with a picture of a horse on it!
Thanks. It should be noted that Redneck Bank have an upper limit of 35k for the high interest rate (1.25%). Otherwise they look cool ;-). But I should mention that for various reasons I am not looking to open savings accounts. I need something that can be managed from inside my Vanguard account. Hence my emphasis on brokered-CD ladders, T-bills, VMMXX and VMFXX in the original post.
Last edited by justinvest on Fri Dec 30, 2016 5:47 pm, edited 1 time in total.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

LadyGeek wrote:
justinvest wrote:Btw, if this thread is better suited for the "theory, news & general" category than the "personal" category, I will not complain if it gets moved by the admins.
That would be me. :) This thread is now in the Investing - Theory, News & General forum (general question).
Thanks, I'm a noob here. Also thanks for the backgrounder on Yankee/Foreign obligations. I had read up on it but I think it improves the thread to have the definitions here.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by dm200 »

Note also that these bank and credit union higher rate accounts are not usually available to organizations (non persons), so for organizations a MM Fund (now that rates have gone up) often pay better rates/returns.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by sperry8 »

There is no point in holding monies in Vanguards Prime MM or other MM's unless it is money you are going to deploy to stock/bonds shortly.

As previously stated there are numerous online banks who pay from 1.1% - 1.25% on up to $250k.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by pkcrafter »

Thanks for posting this, justinvest. My first thought after reading the information provided here was I don't want to own them. Then I found another article that has put me back on the fence.

http://www.bankrate.com/finance/investi ... urn-1.aspx

Page one is encouraging, pg two addresses the down side.

Paul
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by lack_ey »

pkcrafter wrote:Thanks for posting this, justinvest. My first thought after reading the information provided here was I don't want to own them. Then I found another article that has put me back on the fence.

http://www.bankrate.com/finance/investi ... urn-1.aspx

Page one is encouraging, pg two addresses the down side.

Paul
The really short-dated commercial paper of higher credit quality issued by foreign banks and companies (which may have significant USD assets and operations) used by Vanguard money market funds are not exactly the same thing as longer-dated Yankee bonds with junk credit ratings.

I don't mean to minimize and can't personally quantify the kind of risk here, but that article doesn't have much to do with explaining it.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

lack_ey wrote: The really short-dated commercial paper of higher credit quality issued by foreign banks and companies (which may have significant USD assets and operations) used by Vanguard money market funds are not exactly the same thing as longer-dated Yankee bonds with junk credit ratings.
Sure, no disagreement on the above quote, but what is it about short-dated "bank notes" (yankee or not) that makes them secure? I'm not talking interest rate risk, since this is short term stuff, but principal risk. Is it a certainty that all the bank notes (etc) in VMMXX, although rated/listed as "First Tier" in the Edgar filings, really

1. are senior secured debt
2. are backed by collateral that can be liquidated at or above originally booked collateral value even if there is big stress in the markets?
3. will survive a claim on first tier capital by depositors, who I think must have higher seniority than any noteholders

Reference:
https://en.wikipedia.org/wiki/Senior_debt
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by Valuethinker »

justinvest wrote:
In summary, VMMXX at 0.73% seems the best MM alternative as far as rate, but how risky and/or illiquid can those yankee/foreign instruments get? I'm not looking for investment chestnut responses of the type "higher rate always means higher risk". I know that already. But if anyone has better insight about how VMMXX might fare in a crisis, based on current holdings, that would be appreciated, In any case I hope my little analysis may be useful to others.
A "Yankee" is a USD security issued in the US by a foreign borrower.

These things will all have an investment grade credit rating, and are short term to maturity (less than 1 year). In normal circumstances, the practical default risk is almost zero.

In a credit crisis, with systemic risk, it is not. And there could be a chain reaction of defaults. However that assumes that foreign companies, if financial institutions regulated in the US by the US regulators, would go broke and be allowed to go broke by parent financial institutions.

What I suspect is much more likely is liquidity restrictions would be imposed, a la the Reserve Fund in the credit crunch, and you would get most of your money back quite quickly, and some of it back with a very long delay (years?) and even some not at all. Depends to a large extent how the regulators act, and if there is a general bailout of some kind.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by Valuethinker »

justinvest wrote:
lack_ey wrote: The really short-dated commercial paper of higher credit quality issued by foreign banks and companies (which may have significant USD assets and operations) used by Vanguard money market funds are not exactly the same thing as longer-dated Yankee bonds with junk credit ratings.
Sure, no disagreement on the above quote, but what is it about short-dated "bank notes" (yankee or not) that makes them secure? I'm not talking interest rate risk, since this is short term stuff, but principal risk. Is it a certainty that all the bank notes (etc) in VMMXX, although rated/listed as "First Tier" in the Edgar filings, really

1. are senior secured debt
Almost certainly not, given these are Money Market instruments (maturity less than 1 year). Usually unsecured. Recall that in the case of the Asset Backed Commercial Paper market, the security offered by the collateral turned out to be more or less meaningless.
2. are backed by collateral that can be liquidated at or above originally booked collateral value even if there is big stress in the markets?
Are these things Repo'd? You would have to check. Repos are asset-backed, the "haircut" is say the 5m overcollateralization in borrowing $100m for $105m of collateral. In practice, in a meltdown scenario, the assets will be worth less than 105m and probably less than 100m. Lower credit quality collateral you can have REPO110 or REPO 115 rather than REPO 105, but the lower quality collateral is likely to fall even more in value.
3. will survive a claim on first tier capital by depositors, who I think must have higher seniority than any noteholders

Reference:
https://en.wikipedia.org/wiki/Senior_debt
In theory senior debtholders have a higher claim than anyone. But we get into bank regulation here, and I am no expert. In practice, depositors tend to get first call -- that's set by the regulation. Then you get bank senior debt, junior etc.

Money market debt will be at the bottom of the totem pole, in with the other unsecured creditors *unless* there are specific collateral carve-outs (eg a Repo is the classic example).

Your protection in this one really is that it's all investment grade, and short term. The historic record of defaults is very low, but the Primary Reserve Fund got caught with significant holdings of Lehman paper. Hence the meltdown, the freeze on redemptions and the workout (which took years, I believe).
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by Valuethinker »

pkcrafter wrote:Thanks for posting this, justinvest. My first thought after reading the information provided here was I don't want to own them. Then I found another article that has put me back on the fence.

http://www.bankrate.com/finance/investi ... urn-1.aspx

Page one is encouraging, pg two addresses the down side.

Paul
There's a confusion here between Bonds and Money Market instruments.

MMs are by definition maturity within 1 year. It's possible to hold bonds that mature within 1 year (I presume) in an MMF. But generally you hold instruments specially issued with up to 1 year maturity.

So don't take your view on these things from information about Yankee bonds.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by pkcrafter »

Lack_ey and Valuethinker, thanks for mentioning the difference/definition of Yankee bonds and Yankee debt instruments.

Paul
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

I should re-iterate that I am not interested in how secure these various instruments are in "normal times". In normal times, principal security is not a concern. One might say that this is the definition of what constitute "normal times". As I mentioned above, what I am trying to gauge is how VMMXX, in particular, will behave under high stress in financial markets. So far there has not been significant information appearing on that topic. And I will emphasize that this is not an easy question to answer with any certainty. Yes, we all (?) know that money market reform (finally implemented 2016-09-15 circa) was instituted exactly for the purpose of allowing MM funds to break the buck, impose liquidity/redemption fees, gating fees, what have you, so that MM funds will not need to be rescued , but will instead, at least in theory, let those investors who are willing to accept losses to sell their holdings and get out without long delays (again, in theory).

That being said, here is some real information to chew on: The asset composition data for VMMXX has been updated, as shown in the below table. Note that the foreign/yankee holdings are now down from 55% to 46%, which is an interestingly large drop since I checked just days ago.

Distribution by issuer (% of fund)
as of 12/31/2016
Prime Money Mkt Fund
Bankers Acceptances 0.0%
Certificates of Deposit 9.8%
Other 3.2%
Repurchase Agreements 13.8%
U.S. Commercial Paper 5.7%
U.S. Govt. Obligations 3.2%
U.S. Treasury Bills 18.2%
Yankee/Foreign 46.1%
Total 100.0%

Also, it is not obvious whether some of the Yankee/Foreign stuff are repo agreements and therefore backed by collateral with a REPO105 or whatever discount. It does not say anywhere I have been able to ascertain.

Further, I have discovered that the FRB website has some material that at least somewhat explains the definition of Tiers 1-3, as well as has data on MM rates being paid by various ratings/tier classes of debtors. This information can be found by following the below links (most of the links are tabs of the same main web page)

https://www.federalreserve.gov/releases/cp/about.htm
https://www.federalreserve.gov/releases/cp/default.htm
https://www.federalreserve.gov/releases/cp/rates.htm

One of the observations that can be made from studying the rate-as-function-of-tier/rating tables is that VMMXX yielding 0.76% is toward the lower end of the yields tabulated, and corresponds to the highest tier/rated assets, although today the lower-expense higher-minimum Admiral Shares version of VMMXX, called VMMRX, yields 0.80% so clearly there are some riskier assets in the mix as well.

Other MM funds are somewhat less selective about their holdings, as can also be seen by studying rates tabulated at http://cranedata.com/ every day. A few days ago, several MM funds from Blackrock and JPM were in the 0.9-1.0% range, but has since dropped down again, it appears.
Last edited by justinvest on Tue Jan 10, 2017 2:56 pm, edited 1 time in total.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

Any XML gurus/hackers on this blog? It would be really cool to be able to parse-and-slice-and-dice and tabulate various pertinent information from the XML files at Edgar (see post 1 for a sample link). I am already aware of many of the various open source XML toolkits, but it seems like a bit of a learning curve. Right now I am getting some rudimentary numbers using grep and sort :-).

If someone knows about some canned scripts for analyzing these Edgar NFMP or NFMP2 report files, that would be really cool. I'm sure Wall St already has this fully automated, but they are not going to share their tools with us. It is not rocket science, but it is work.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by LadyGeek »

Just in case, the wiki has some background info on the various formats. See: EDGAR database XBRL is the interface language.

If you follow the links, eventually you'll get to the EDGAR Filer Manual. XML is discussed in Chapter 10. Aside from that, I can't help you much further.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

It's not so much the format that needs explaining. I can easily read an N-MFP2 style XML file or document into (say) emacs text editor XML-mode, and see exactly what the internal structure of the file is. What I'm talking about is massaging the data and perform calculations, and make reports, from the data. Specific formulas based on XML tags, cumulative calculations, and the like.

This is probably way too technical for many bogleheads. That's why I was asking if there were any XML hackers around, or what is called data scientists these days, in particular people with technical chops in data mining from XML.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by garlandwhizzer »

VMMXX is in my opinion one of the safest places in the world to park money and preserve capital, safer than any short term or intermediate term bond instrument for that purpose. The weighted average life of the credit instruments in their portfolio is 88 days, less than 3 months, and their credit quality as judged by Vanguard (which knows a lot about credit risk) is uniformly high. They refer to it as "one of the most conservative investment options offered by Vanguard." I do not believer the label of "Yankee Foreign" in their credit portfolio carries any risk other than psychological.

In the depths of the crisis of 2008, when there was widespread fear that the entire global financial system itself would completely collapse, when banks refused to lend money to each other or to private parties out of fear, when the entire credit system locked up, both Vanguard and the US government vowed to support the stable principal value of well run money market funds like VMMXX and let us be assured that VMMXX is well run in a conservative manner by Vanguard. Quality credit instruments with less than 90 day durations cannot collapse in value because if they did, the entire worldwide financial system which depends massively every day on these instruments to settle accounts would collapse with it. If that happens to VMMXX there will be such a global financial disaster that the promise of any credit issuer including the US government to pay you in 3, 5, or 10 years will be worth little more than the paper it's written.

There are some real things in financial markets to worry about at present. The security of VMMXX is not in my opinion one of them.

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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by Valuethinker »

garlandwhizzer wrote:VMMXX is in my opinion one of the safest places in the world to park money and preserve capital, safer than any short term or intermediate term bond instrument for that purpose. The weighted average life of the credit instruments in their portfolio is 88 days, less than 3 months, and their credit quality as judged by Vanguard (which knows a lot about credit risk) is uniformly high. They refer to it as "one of the most conservative investment options offered by Vanguard." I do not believer the label of "Yankee Foreign" in their credit portfolio carries any risk other than psychological.

In the depths of the crisis of 2008, when there was widespread fear that the entire global financial system itself would completely collapse, when banks refused to lend money to each other or to private parties out of fear, when the entire credit system locked up, both Vanguard and the US government vowed to support the stable principal value of well run money market funds like VMMXX and let us be assured that VMMXX is well run in a conservative manner by Vanguard. Quality credit instruments with less than 90 day durations cannot collapse in value because if they did, the entire worldwide financial system which depends massively every day on these instruments to settle accounts would collapse with it. If that happens to VMMXX there will be such a global financial disaster that the promise of any credit issuer including the US government to pay you in 3, 5, or 10 years will be worth little more than the paper it's written.

There are some real things in financial markets to worry about at present. The security of VMMXX is not in my opinion one of them.

Garland Whizzer
G/W

I don't disagree with your general conclusion

BUT

I believe there have been post bailout court cases which might make it impossible/ difficult for the US government to intervene in a financial crisis in the same manner. I am vague on the details, but some actions by the US govt were subsequently deemed to have been illegal.

In that sense, we can't argue past events are a guide to future actions.

One of the points of the MMF reform was to make it clear to investors that they are taking risk, I believe.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by lack_ey »

justinvest wrote:It's not so much the format that needs explaining. I can easily read an N-MFP2 style XML file or document into (say) emacs text editor XML-mode, and see exactly what the internal structure of the file is. What I'm talking about is massaging the data and perform calculations, and make reports, from the data. Specific formulas based on XML tags, cumulative calculations, and the like.

This is probably way too technical for many bogleheads. That's why I was asking if there were any XML hackers around, or what is called data scientists these days, in particular people with technical chops in data mining from XML.
Yeah, like you I don't really know these tools and would have grepped and sorted like you did. I know enough to know what you're asking but not what actually to do.

I think there are some who might know, but a problem is that this whole topic is really not much interest to anybody here as you can get higher FDIC-insured yields elsewhere so who cares about money market funds?
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

garlandwhizzer wrote:VMMXX is in my opinion one of the safest places in the world to park money and preserve capital,
Garland Whizzer
Well, the fact remains that Vanguard *itself* does not think VMMXX is safe enough to clear their own customer's trades through it. I mentioned the realities of the MM fund regulation reforms of 2016 earlier, and those reforms are the reason why VMMXX is not deemed safe enough. Instead, customers must, since about 2016-09-15, use VMFXX as the clearing fund in all accounts. VMFXX supposedly contains only USG and "agency" securities. I'm willing to stipulate that VMFXX is rock solid. I am not willing to stipulate that VMMXX is.

This the reason why I asked about the safety of VMMXX in the first place.

(USG = US Government)
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by garlandwhizzer »

justinvest wrote:
Well, the fact remains that Vanguard *itself* does not think VMMXX is safe enough to clear their own customer's trades through it. I mentioned the realities of the MM fund regulation reforms of 2016 earlier, and those reforms are the reason why VMMXX is not deemed safe enough. Instead, customers must, since about 2016-09-15, use VMFXX as the clearing fund in all accounts. VMFXX supposedly contains only USG sand "agency" securities. I'm willing to stipulate that VMFXX is rock solid. I am not willing to stipulate that VMMXX is.
Good point, but it's important to remember that Vanguard's shift into VMFXX for a settlement fund was based on SEC regulatory changes, not any loss in principal value from the 2008-9 crisis which by the way was by far the worst global financial crisis in the prior 80 years since the Great Depression. Not one cent of VMMXX principal value was lost in that terrible crisis, so it takes a yet greater disaster to make that impact. You're talking about choosing a money market fund based on preparation for a 5 or 6 or more sigma event here, the blackest of black swans, something that is unlikely to happen in our lifetime. If you have serious concerns about such an event, it's probably best to put your money in VMFXX or a FDIC insured savings account which is also backed by the government and, as others have pointed out, yields more.

When we're talking extreme black swans one to consider also is default by the US government to fulfill its debt obligations. The list of countries that have defaulted on sovereign debt at some point includes France, England, Netherlands, Germany, Austria, Spain, Russia in addition to the usual suspects. When investors bought those bonds they believed them to be as safe as VMFXX. Things like a nuclear war or nuclear terrorist attack, an giant asteroid strike on the US mainland, the mega-eruption of the Yellowstone Super-volcano (which has happened catastrophically several times in the past), etc., can drastically affect the ability of the US government to meet its obligations without resorting to inflating away the debt away by excessive printing of money as Germany did in the post-WW1 period. In that case bond holders get paid nominal returns it doesn't buy much.

It's a personal decision, but I'm sticking with VMMXX for my money market exposure.

Garland Whizzer
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

Here is some reference material on the 2008 crisis and the associated troubles in money market funds. This article is from the wiki at this very site, bogleheads.org, and I found it quite informative and a good refresher/backgrounder for those who may not know or remember many of the details,

https://www.bogleheads.org/wiki/The_200 ... ket_crisis

I have some more remarks I'd like to make, but no time the last few days. More later, hopefully.
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

>>Good point, but it's important to remember that Vanguard's shift into VMFXX for a settlement fund was based on SEC regulatory changes,

Short version:

The above is not a false statement, but I think still a very misleading one. The SEC did not say, explicitly or implicitly, that Vanguard could not continue to use VMMXX as the designated settlement fund for securities trading. SEC also did not decree that Vanguard had to use the more safe VMFXX fund for settlements. Making the choice of only allowing VMFXX for settlement funds was a choice that Vanguard itself made!!

Long version:

OLD SEC RULES: A money-market fund (MMF) could be frozen (meaning: redemptions disallowed) if the MMF operator deemed that MMF depositors would lose money if other depositors were permitted to withdraw their money.

NEW SEC RULES: An MMF can no longer freeze a fund, but can/will instead impose "liquidity fees" or "gating fees" so that those sellers who want to sell will cover the losses caused by having to sell securities at less than par/booked value.

The problem is that even with gating fees, one cannot easily guarantee that some losses will not eventually be borne by the remaining holders of the MMF. Vanguard deemed that, in order to protect Vanguard itself (and Vanguard's clients) against potential losses that might exceed the proceeds from the gating fee, Vanguard would no longer allow VMMXX to be used as a source of payment for security trades (stocks, bonds, whatnot). THIS WAS A CHOICE MADE BY VANGUARD. It was not imposed by the SEC. The choice was a logical consequence of the rule to disalow MMF freezes, but it was a choice that Vanguard made by itself.

>>not any loss in principal value from the 2008-9 crisis.

It is correct that no VMMXX shareholder lost any money in 2009, and indeed that VMMXX was never frozen. But it could have become necessary to freeze, and now that freezing is no longer allowed, there is no way to guarantee that losses will not occur in a future crisis. Therefore, Vanguard made the choice to disallow VMMXX as the source of payment (settlement) for trades.

Summary: The SEC did not impose on Vanguard that they had to use VMFXX as the settlement fund. Rather, Vanguard made that choice because Vanguard realized that that it could not guarantee that VMMXX would not suffer losses under extreme market conditions under the new rules.

Finally, I'm sure everyone understands that a mutual investment company (like Vanguard) nor conventional stock brokerage (like Schwab or whoever) will not come out and srtate outright that "Under extreme market conditions we will not be able to guarantee the safety and liquidity of money deposited in our main MMF, so we will require instead that our customers use a government-security-only MMF to pay for trades". No financial company wants to make such a statement. So instead they make a wooly statement along the lines of "the change was caused by SEC regulatory changes", although that is not really the full truth.
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welderwannabe
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by welderwannabe »

justinvest wrote: Sun Feb 18, 2018 9:06 pm The above is not a false statement, but I think still a very misleading one. The SEC did not say, explicitly or implicitly, that Vanguard could not continue to use VMMXX as the designated settlement fund for securities trading. SEC also did not decree that Vanguard had to use the more safe VMFXX fund for settlements. Making the choice of only allowing VMFXX for settlement funds was a choice that Vanguard itself made!!

Long version:

OLD SEC RULES: A money-market fund (MMF) could be frozen (meaning: redemptions disallowed) if the MMF operator deemed that MMF depositors would lose money if other depositors were permitted to withdraw their money.

NEW SEC RULES: An MMF can no longer freeze a fund, but can/will instead impose "liquidity fees" or "gating fees" so that those sellers who want to sell will cover the losses caused by having to sell securities at less than par/booked value.

The problem is that even with gating fees, one cannot easily guarantee that some losses will not eventually be borne by the remaining holders of the MMF. Vanguard deemed that, in order to protect Vanguard itself (and Vanguard's clients) against potential losses that might exceed the proceeds from the gating fee, Vanguard would no longer allow VMMXX to be used as a source of payment for security trades (stocks, bonds, whatnot). THIS WAS A CHOICE MADE BY VANGUARD. It was not imposed by the SEC. The choice was a logical consequence of the rule to disalow MMF freezes, but it was a choice that Vanguard made by itself.
I think you need to research this a little further, because I find your post somewhat misleading. A fund can in fact impose a redemption fee and/or impose a gate. A gate is a temporary suspension of redemptions from the fund for a period of time. In other words, it is a 'freeze'. There is no disallowing of freezing redemptions under the new regulations and I am not sure where you got that from.

The SEC also requires that any money market offered to non-persons (in other words organizations, companies etc) MUST have a floating NAV unless it invests solely in government securities. This is really the reason why Vanguard changed to the Federal. Had they left it as a prime, they would have had to use a floating NAV for any company/club/organization's account. A floating NAV can be a real PITA at tax time, and has obvious problems when used as a settlement fund as the value of your 'cash' could actually fluctuate between the time a trade is placed and the time it is settled.

Vanguard did a nice writeup on this here: https://investor.vanguard.com/mutual-fu ... et-reform/

A summary is below:
* A fund may impose a fee of up to 2% on redemptions if a fund's weekly liquid assets fall below 30% of its total assets.
* A fund must impose a 1% fee on redemptions (with the option of imposing a fee of up to 2%) if a fund's weekly liquid assets fall below 10% of its total assets—unless the fund's board determines a fee would not be in the fund's best interest.
* A fund may impose a gate—that is, suspend redemptions—for up to 10 business days in a 90-day period.

The fees and gates rules only apply to retail and institutional funds, although government funds may voluntarily adopt them if the fees and gates are previously disclosed to investors.
I am not an investment professional, but I did stay at a Holiday Inn Express last night.
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justinvest
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Re: VMMXX-Vanguard Prime Money Market is 55% Yankee/Foreign

Post by justinvest »

@welderwannabe

>>I think you need to research this a little further, because I find your post somewhat misleading.

Hold on just a minute

>> A fund can in fact impose a redemption fee and/or impose a gate.

That's exactly what I said. We are in agreement. How am I misleading again? Not sure why you thought I said something I didn't say, but perhaps you skimmed a bit too fast and missed the part of me describing OLD versus NEW rules from SEC?

Thanks for the added details on the redemption/gating fee criteria, sizes, and time constraints, though :-).
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