Fidelity also
said that all costs and benefits should be enumerated and evaluated before
regulators seek to make further structural changes to a well-functioning
investment vehicle that serves the needs of short-term investors and borrowers.
Moreover, additional reforms should be carefully considered prior to
implementation to ensure that they are consistent with creating a stronger,
more resilient product, without imposing harmful, unintended consequences on financial
markets or on the global economy.
The investment
firm urged the European Commission and other regulators globally to consider
some of the existing key features and principles that the firm deems as best
practices for money market funds. Regulators were encouraged to codify these
features and principles by including them directly in the definition of a money
market fund. These practices include constraints on the liquidity, maturity,
diversification, and credit quality of money market funds, as well as
transparency and clear governance requirements.
The investment
firm also asked regulators to expand their focus beyond money market funds to
examine investment products that remain unregulated and non-transparent in the
money markets. Rather than concentrating effort on removing the essential
features of money market funds that have made these funds a successful
innovation in the financial markets, the investment firm urged international
securities regulators to bring regulation for the first time to the numerous
pools and structured vehicles that offer cash investment without the strict
rules under which money market funds operate.