According to recent press reports, the Securities and Exchange Commission (SEC) is considering releasing a controversial proposal to impose additional capital and liquidity regulations on the $2.7 trillion money market fund industry (MMMFs) and to replace the fixed $1 net-asset value ("par value") rule now used by all MMMFs to redeem customer funds with a mark-to-market (NAV) requirement. 

With the recent publication of its final rule, the federal government's Financial Stability Oversight Council is now in position to designate certain nonbank firms as "systemically important financial institutions" (SIFIs). There is probably no aspect of the Dodd-Frank Act that will have more damaging effects on competition in the U.S. financial system.

The financial crisis has highlighted the institutional features of our financial system and regulatory policies that unexpectedly resulted in financial instability.

The Committee believes that the federal safety net that was extended to money market mutual funds could be removed by marking their portfolios to market on a daily basis.

The Shadow Financial Regulatory Committee (SFRC) is a group of publicly recognized independent experts on the financial services industry--including banking, insurance and securities--who meet regularly to study and critique regulatory policies affecting this sector of the economy.

Under the Dodd-Frank financial-reform law, large nonbank firms may be declared systemically important because their failure will cause a systemic breakdown. In effect, this amounts to a government statement that these firms are too big to fail.

In a new book entitled “Financing Failure: A Century of Bailouts,” Vern McKinley provides the most detailed account yet of the government’s decision-making process during these momentous events.

The underlying idea—that financial institutions are "interconnected" and the failure of one will drag down others - is not implausible. But like so much else that underlies the Dodd-Frank Act, it was accepted as true—and acted upon—without much evidence, or even much thought.