Operational Implications of a Floating NAV across Money Market Fund Industry Key Stakeholders

The purpose of this paper is to explore the dramatic cost and operational impact of what might seem to be a small change in share price accounting protocol. The research in this paper examines the compliance costs across key stakeholders within the MMF industry if all MMFs changed to a floating NAV. We believe that the loss of economies of scale associated with a dual system of pricing some funds on a fixed NAV basis and others on a floating NAV basis—as the SEC has proposed—would be more expensive and complicated than the costs and system upgrades described in this paper.