It has been fascinating to watch market attention shift following the conclusion of the Fed’s Quantitative Tightening (QT) program on December 1st.

The focus appears to have now shifted to the Fed’s upcoming purchase of T-Bills to manage liquidity.

Ah, and that still leaves the Interest on Reserve Balances (IORB) as the elephant in the room.

To me the IORB remains a structural anomaly; something that has quietly created a regulatory arbitrage for the largest banks, particularly since rate tightening began in March 2022.

The largest U.S. banks earn the IORB rate (currently approx 3.90%) on the reserves they park at the Fed.

In a parallel world, they pay the average retail saver a fraction of that on standard savings accounts (~ 0.4%)

This spread represents a vast, risk-free profit margin – a guarantee from the Fed on funds that they [the Commercial Banks] have acquired at the cheapest possible rate.

You could slice it and dice this anyway.

This is, by any definition, an ANOMALY.

It deserves far more scrutiny than it receives currently.

But first, the backstory: why did the IORB come into existence?

While politically charged (with Congress periodically seeking to abolish it), the IORB is possibly here to stay because it is the lynchpin of modern monetary policy.

The IORB’s primary function is to provide a floor for interest rates, effectively replacing the pre-2008 Inter-Bank Lending Market.

It eliminates the need for banks to lend to one another (which could and had indeed led to the notorious credit freeze of 2008), incentivizing them to park reserves with the Fed for a risk-free return, thereby guaranteeing the Fed’s control over the short-term rate.

And despite the congressional pressure on the Fed to eliminate the IORB (and go back to the zero-interest-paid-on reserves era prior to the GFC), it [IORB] is likely to remain because who would really want to take a chance with bank credit risk again?

So, what does a saver really do in a situation like this?

Well, since a savings account holder cannot open an account at the Fed to get the IORB rate, the smartest move then for cash management is to exploit the very market dynamics the Fed created:

Instead of leaving cash in low-yield savings accounts, the most rational approach is to invest them into Money Market Funds (MMFs) instead.

MMFs, in turn, invest in high-quality short-term assets (T-Bills, Treasuries, and highly liquid securities) or execute Overnight Reverse Repurchase Agreements (ON RRP) directly with the Fed.

This then allows a saver to bypass the bank’s low-paying deposit window and earn a rate much closer to the Fed Rate.

The anomaly still remains.

But this is your best bet at making the most of it.

By

Avinash Menon, CFA

Founder and CEO,

52 Seconds Capital Limited

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Yesterday’s news that the SEC is halting the review of proposals for extreme (3x to 5x) leveraged single-stock and broader indices ETFs is significant.

This regulatory action is a direct consequence of SEC Rule 18f-4, the comprehensive framework implemented to manage derivatives risk in registered funds.

The 18f-4 rule establishes a hard boundary on new leverage by mandating that a fund’s daily Value-at-Risk cannot exceed 200% of its benchmark index’s VAR.

In essence, 2x is the absolute legal ceiling for new leveraged products.

However, a glaring inconsistency remains: 3x leveraged ETFs, most notably ProShares UltraPro QQQ ETF.

TQQQ was launched in 2010, long before the 200% VaR limit was finalized.

The SEC allowed these pre-existing 3x funds to continue operating under their original mandates, effectively exempting them from the 200% VaR cap.

So, as of yesterday, we now have a glaring, two-tiered system where the market’s most popular 3x leveraged fund is structurally permitted to carry a level of risk the SEC deems too dangerous for any new product application.

The risk of TQQQ (or even the 2X leveraged ones) is not simply that losses are magnified three times. You must understand that the risk lies in the mathematical certainty of the daily leverage reset, which introduces two severe risks:

1. Volatility Decay / Compounding Risk: In volatile or choppy markets, the daily rebalancing causes the fund’s long-term performance to diverge drastically and negatively from 3x the index return. The fund prospectus explicitly warns that returns for periods longer than a single day will ‘likely differ significantly’ from the target due to this compounding effect (See image to see how the losses stack up, source:

https://lnkd.in/dxGjkdeF

2. Zero-Out Risk: The 3x structure mathematically exposes investors to a potential wipe out. Read that again: A WIPE OUT. The fund’s prospectus carries this stark warning: If the Index approaches a 33% loss at any point in the day, you could lose your entire investment (This line is from the summary prospectus of the ETF)

I am not taking aim at TQQQ here (or at any of the other 3x or 2x products), indeed these ETFs serves a niche function for highly sophisticated traders and for short-term tactical trades.

But given the risks – amplified by leverage and compounding – before considering participation in TQQQ or similar grandfathered products, you must engage in a detailed discussion with your Financial Advisor (preferably a licensed and regulated one!)

By

Avinash Menon, CFA

Founder and CEO,

52 Seconds Capital Limited

Other New Articles