On October 9, 2012, the International Organization of Securities Commissions (“IOSCO”) released a final report calling for additional regulation of money market funds (“MMFs”), including options for a floating NAVs, NAV buffers and liquidity fees.

The Financial Stability Board (FSB), established by the heads of state of the “Group of 20,” considers MMFs to be part of a “shadow banking system” because they are important sources of short-term funding, particularly for banks. For this and other reasons, the FSB urged IOSCO to review potential regulatory reforms of MMFs that would mitigate their susceptibility to runs and other systemic risks and to develop policy recommendations. FSB indicated that a key issue for consideration was the stable net asset value feature of MMFs.