Capital Markets Volatility and COVID-19: Background and Policy Responses

June 19, 2020 R46424

Capital Markets Volatility and COVID-19:
June 19, 2020
Background and Policy Responses
Eva Su
Capital markets provide major sources of financing and investment for American businesses and
Analyst in Financial
investors by facilitating the creation and trading of securities, such as stocks, bonds, and shares of
Economics
investment funds. During the COVID-19 pandemic, certain markets ceased generating

transactions, or the transactions became abnormally expensive as participants demanded a higher
risk premium. The uncertainties surrounding the crisis have led to increased volatility, meaning

increased price fluctuation and dispersion, a common indicator of risk and stress. Although the
pandemic has substantially reduced business activities, a large portion of these activities are expected to resume eventually.
However, the timing and extent of the economic recovery are uncertain.
COVID-19-related market reactions, including broad capital market selloffs and rebounds, and policy responses have been
marked by their speed. Congress passed some of the largest and fastest interventions in history, including the Coronavirus
Aid, Relief, and Economic Security Act (CARES Act; P.L. 116-136). The Federal Reserve, sometimes with support from the
Treasury Department, has established several facilities to provide emergency lending to selected capital markets segments. A
key policy goal during the pandemic is to allow businesses and capital markets to remain functional so they can meet
demands at the time of need. The crisis-induced stress conditions have been broadly felt in all corners of capital markets.
Stocks, corporate bonds, investment funds, and others have all experienced selloffs . The coronavirus triggered both liquidity
and solvency concerns, though some of the conditions for volatility have been brewing for years.
Stocks. The pandemic ended a record-long 11-year U.S. stock market bull run in March 2020, representing the quickest
drawdown on record. Stock prices are forward-looking, generally reflecting the market’s expectations of a company’s worth
in the future. In the context of pandemic-induced market stress, earnings estimates and other factors feeding into valuation
estimates decreased due to pandemic-related revenue losses. In addition, market stress often causes stock prices to decouple
from underlying corporate fundamentals, with market psychology and liquidity crunches adding to stress levels. Reactions to
market stress can also seize up the financial “plumbing,” as firms desperate for cash rush to liquidate stocks, further
distancing immediate stock prices from firms’ underlying valuations. The Securities and Exchange Commission’s (SEC’s)
policy tools to calm market volatility include circuit breakers and limit up-limit down mechanisms. There have also been
federal government fiscal and liquidity interventions during the pandemic, which have eased companies’ pressure for cash
and liquidity. The stock market rebounded following the anticipation of such interventions.
Corporate bonds. Prior to the COVID-19 pandemic, U.S. companies were carrying record levels of debt to finance their
operations, with a major portion of this corporate debt in higher-risk positions relative to historical levels. Policymakers and
market observers have been concerned that, during a market downturn, funding costs and availability might change, driving
already risky companies to defaults and business closures. Such funding dislocation could undermine financial system
liquidity and amplify financial and economic vulnerabilities. To keep capital markets functioning in the current crisis, the
federal government has acted to provide broad support for segments of the corporate bond market, allowing them to rebound.
In addition, policy discussions have addressed the manner in which credit rating agencies assign bond credit ratings, which in
turn influence a bond’s borrowing costs and liquidity. Ratings inflation, market concentration, and conflicts of interest by
credit rating agencies have been policy concerns since the 2007-2009 financial crisis.
Funds. Investment funds, such as mutual funds and exchange-traded funds (ETFs), are pooled investment vehicles that
consolidate money from investors and manage it for a fee. During crisis conditions, some mutual funds may be susceptible to
sudden large redemptions (runs) if investors have an incentive to redeem shares before others do when there is a perception
that the fund could suffer a loss. ETFs might also behave irregularly, with an ETF’s share price decoupling from the value of
its underlying holdings. The fund market has also experienced high volatility due to COVID-19. Some funds received new
sources of liquidity through the SEC’s temporary allowance of certain interfund lending and the federal government’s
emergency intervention programs.
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Capital Markets Volatility and COVID-19: Background and Policy Responses

Introduction
Capital markets are where securities—such as stocks, bonds, and shares of investment funds—are
issued and traded. They provide the largest sources of financing for U.S. nonfinancial companies.
Companies obtain funding by sel ing stocks or borrowing from the bond markets. Stocks, also
cal ed equities or shares, represent an ownership interest in a firm. Bonds, also cal ed fixed
income or debt securities, refer to the indebtedness or creditorship of a firm or a government
entity. Investment funds are pooled investment vehicles that gather and invest money from a
variety of investors. U.S. capital markets for financing are mainly regulated by the Securities and
Exchange Commission (SEC) and self-regulatory organizations (SROs).
Participants in U.S. capital markets include about 7,600 companies that report to the SEC, of
which approximately 4,400 are exchange-listed public companies; more than 28,000 investment
advisers, mutual funds, exchange-traded funds, broker-dealers, and other registered entities; and
mil ions of domestic and foreign retail and institutional investors.1 The annual trading volumes of
stocks and bonds are approximately $100 tril ion and $40 tril ion, respectively, and reported
assets under management at SEC-registered investment advisors amount to around $80 tril ion.2
This report focuses on capital markets behavior and policy responses in reaction to the COVID-
19 economic crisis, with particular focus on stocks, corporate bonds, and investment funds. The
report aims to provide context for understanding policy decisions, their perceived outcomes, and
the pros and cons of certain policy actions.
Normal Market Conditions Versus Crisis
Conditions
Under normal conditions, capital markets provide reliable sources of financing for businesses.
Businesses can obtain such funding by, for example, issuing stocks and bonds. The funding can
then be used for equipment purchases, research and development, employee salaries, or any other
functions that facilitate operations and growth. Institutions and households can partake in these
growth opportunities by investing in stocks, bonds, and funds, with the hope of future returns.
In crisis conditions, including during the COVID-19 pandemic, normal capital markets functions
can come to a halt. Certain markets may no longer generate transactions, or the transactions may
become abnormal y expensive. Normal funding channels can become unreliable, creating funding
shortages for businesses and financial losses for investors. Furthermore, businesses and investors
might start to hoard cash and sel risky assets. These activities may lead to asset devaluation, fire
sales, and bankruptcies that may have a negative ripple effect on the broader economy.
The uncertainties surrounding crisis conditions can increase volatility, meaning markets
experience greater price fluctuation and dispersion.3 Volatility is a common indicator of risk—

1 U.S. Securities and Exchange Commission (SEC), Fiscal Year 2021 Congressional Budget Justification Annual
Perform ance Plan, at https://www.sec.gov/files/secfy21congbudgjust.pdf#page=6.
2 SEC, Fiscal Year 2021 Congressional Budget Justification Annual Performance Plan .
3 Volatility is a statistical measure of the degree of variation in a financial instrument’s trading price observed over a
period of time. It can be historical or implied, and volatility itself can also be a tradable market instrument. A market
index, called the VIX index, is often used to measure the market’s expectation of 30 -day forward-looking volatility
using inputs from S&P 500 options. T his report does not cover the technical details of volatility.
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excessive volatility often coincides with market turmoil or high levels of uncertainty. High-
volatility events have regularly occurred throughout financial history (Figure 1).
Figure 1. Modeled Volatility (VIX Index) Over a Century

Source: BNP Paribas, 100 Years of Crashes: COVID-19 Crisis Playbook, April 17, 2020.
Note: The VIX index is a market index that measures the market’s expectation of 30-day forward-looking
volatility using inputs from S&P 500 options.
How Is This Time Different?
Forward projections of earnings and economic performance drive capital markets pricing.
Economic and earnings uncertainties during the COVID-19 pandemic present unique chal enges
that could fuel market volatility. The COVID-19 pandemic has created a period of lost economic
activity induced by public health concerns, rather than a crisis originating from the financial
services sector, as was experienced in 2007-2009. The economy—as measured by gross domestic
product (GDP) growth and corporate earnings—was relatively strong prior to the pandemic. One
index that measures the GDP-weighted share of the country that has shut down activities (e.g.,
schools, non-essential businesses, and issued stay-at-home orders) reached 86% in April 2020
(Figure 2). There were estimated 50% declines in activities at workplaces and retail stores and a
25% increase in activities at home. A large portion of these declines are expected to reverse once
the pandemic is under control, but uncertainties exist regarding how and when the recovery might
occur.
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Figure 2. U.S. Activity Declines vs. Pre-COVID-19, GDP-Weighted, % Change

Source: Goldman Sachs Global Macro Research, Reopening the Economy, April 28, 2020.
One notable feature of market reactions and policy responses to COVID-19 has been their
speed—the speed of market sel offs (Figure 5) as wel as the speed of congressional action.
Congress acted to provide some of the largest and fastest interventions in history in a crisis
environment (Figure 3).
Figure 3. Government Spending as Share of GDP
(as of 4/19/2020)

Source: Bank of America Research Investment Committee. Robin Wiggleworth, “Coronavirus Creates Biggest
Economic Uncertainty in Decades,” April 19, 2020, at https://www.ft.com/content/4d77ab77-0ff0-46ff-b30e-
ae712c582457.

Notes: WWI = World War I; WWII = World War II; GFC = the 2007-2009 global financial crisis.
Among other policy goals, congressional action has aimed to al ow businesses to stay solvent so
they can return to meet increased demand as social distancing and stay-at-home orders come to an
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end. In general, the longer the businesses are disrupted, the harder it is to recover. But the
lockdown’s duration is largely dependent on health care factors relating to testing, treatment, and
immunity, as wel as the political wil to lift restrictions.
The COVID-19 pandemic could affect investor and consumer behavior in profound ways. Some
of these changes could have longer-term financial implications. Some argue that after the
pandemic is over, Americans may enter a period of austerity and become more cautious about
investing and consumption, affecting business growth and investable assets. For example, the
household savings rate went up considerably after the Great Depression. Certain habits and
activities cultivated during the quarantine period could also become more permanent. For
example, the large-scale teleworking undertaken during the pandemic may change work habits. If
a portion of the teleworking becomes more permanent, markets such as commercial real estate
may experience ramifications.
Past pandemics provide mixed evidence for the lasting impact of such events. Some believe past
pandemics’ adverse effects were short term, whereas others argue that they were long lasting. For
example, one study suggests that industrial output fel sharply during the 1918 flu pandemic but
rebounded within months, and that the adverse economic effects captured in the study were short
lived.4 Another study of 15 major pandemics suggests that their adverse macroeconomic after-
effects lasted about 40 years.5
Capital Markets Volatility and COVID-19
This section discusses how stressful conditions are observed in the markets for stocks, corporate
bonds, and funds. The subsections relating to each of these three components identify key
concerns, discuss selected market segments and their stress conditions, and describe policy
responses to these conditions as wel as their effects.
Stocks
Stocks, also cal ed equities, are shares of ownership in a public company, general y listed on a
national securities exchange. The stock market consists of around 4,400 companies with a
combined market capitalization of more than $30 tril ion (Figure 4).6 In broad usage, the stock
market also refers to the public offering and trading of shares in investment funds and other
financial instruments. Around half of U.S. households own stock investments.7

4 Francois Velde, What Happened to the US Economy During the 1918 Influenza Pandemic? A View Through High-
Frequency Data, Federal Reserve Bank of Chicago Working Paper no. WP-2020-11, April 17, 2020, at
https://www.chicagofed.org/publications/working-papers/2020/2020-11.
5 Oscar Jorda, Sanjay R. Singh, and Alan M. T aylor, Longer-Run Economic Consequences of Pandemics, Federal
Reserve Bank of San Francisco Working Paper no. 2020-09, March 2020, at https://www.frbsf.org/economic-research/
files/wp2020-09.pdf.
6 As compared to the 2018 U.S. gross domestic product of $20 trillion. Market capitalization refers to the market value
of a company’s outstanding shares of stock. For more details, see SEC, Office of the Advocate for Small Business
Capital Form ation FY2019 Annual Report, December 19, 2019, at https://www.sec.gov/files/
2019_OASB_Annual%20Report.pdf#page=30; and Bureau of Economic Analysis, Gross Dom estic Product, Fourth
Quarter and Annual 2018 (Initial Estim ate), February 28, 2019, at https://www.bea.gov/news/2019/initial-gross-
domestic-product -4th-quarter-and-annual-2018.
7 Kim Parker and Richard Fry, “More T han Half of U.S. Households Have Some Investment in the Stock Market,” Pew
Research Center, March 25, 2020, at https://www.pewresearch.org/fact -tank/2020/03/25/more-than-half-of-u-s-
households-have-some-investment-in-the-stock-market.
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Figure 4. U.S. Stock Market: Publicly Listed Companies and Their Market
Capitalization

Source: SEC, Office of The Advocate for Smal Business Capital Formation Annual Report for Fiscal Year 2019, at
https://www.sec.gov/files/2019_OASB_Annual%20Report.pdf#page=30.
The stock market provides a means of fundraising and trading for businesses and investors. These
activities direct money into businesses that the investment community believes to be the most
promising for growth and returns. As such, the stock market functions to al ocate assets, drive
economic growth, provide liquidity, and facilitate savings and investments. The market also offers
a barometer for the health of the business and economic environments.
The Dow Jones Industrial Average or S&P 500 (indexes that comprise 30 and 500 large listed
companies, respectively) are often used to gauge the stock market’s movements.8 The stock
market’s overal performance general y follows underlying business and economic conditions and
enters into bull or bear runs.9
Rapid Bull and Bear Transitions
The COVID-19 pandemic ended an 11-year U.S. stock market bull run in mid-March, resulting in
the quickest drawdown on record (Figure 5).10 The market subsequently rebounded to an extent,

8 T he Dow Jones Industrial Average is a 30-stock, price-weighted index that measures the performance of some of the
largest U.S. companies. T he index covers all industries except for transportation and utilities. T he S&P 500 is based on
market capitalization and measures the performance of 500 large-cap companies covering around 80% of available
market capitalization. For more details, see S&P Global, “ S&P 500,” at https://us.spindices.com/indices/equity/sp-500,
and “Dow Jones Industrial Average,” at https://us.spindices.com/indices/equity/dow-jones-industrial-average.
9 Fidelity, “ Sector Investing Using the Business Cycle,” May 31, 2019, at https://www.fidelity.com/viewpoints/
investing-ideas/sector-investing-business-cycle.
10 T om Westbrook and Scott Murdoch, “How the Longest Bull Run in History Ended in Pandemic Panic,” Reuters,
March 13, 2020, at https://www.reuters.com/article/us-health-coronavirus-markets-ticktock/how-the-longest-bull-run-
in-history-ended-in-pandemic-panic-idUSKBN21038A.
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following liquidity interventions by the Federal Reserve and Congress’s $2 tril ion coronavirus
relief package (P.L. 116-136).11
Figure 5. Quickest Drawdown for U.S. Stocks on Record
(the number of trading days it took for the S&P 500 index to drop 30%)

Source: Bank of America Global Research. Yun Li, “This was the fastest 30% sel -off ever, exceeding the pace of
declines during the Great Depression,” CNBC, March 23, 2020, at https://www.cnbc.com/2020/03/23/this-was-
the-fastest-30percent-stock-market-decline-ever.html.
Securities Valuation During Market Stress
Stock prices are forward looking, general y reflecting the market’s expectations of a company’s
worth. These expectations are informed by different methods of determining a company’s
underlying value. For example, the discounted cash flow model calculates the current value of a
company’s future income stream, whereas multiples analysis gauges a company’s worth using
multiples of its existing earnings or sales, among other measures.12 These fundamental analyses
aim to calculate a firm’s intrinsic value for comparison with its stock price and al ow investors to
determine whether they should buy or sel .
In the context of the coronavirus-induced market stress (Figure 6), does market volatility mean
that companies’ underlying financial conditions suddenly changed, or are there other factors that
come into play? The answer seems mixed. Earnings estimates and other factors feeding into
valuation estimates certainly have changed. For example, the coronavirus directly reduced
economic activities in certain industries. The virus might also indirectly reduce companies’
outlooks because certain macroeconomic conditions have worsened (e.g., higher unemployment
rate, reduced spending, and the threat of widespread bankruptcies), further suppressing stock
prices. Such economic effects, however, do not tel the whole story. Stock prices can often
decouple from underlying corporate fundamentals during market turmoil, with market
psychology and liquidity crunches adding to stress levels. Reactions to market stress can also

11 For more details on the capital markets reactions toward the liquidity interventions, see CRS Insight IN11340,
COVID-19: Selected Capital Markets Segm ents Supported by Federal Governm ent Liquidity Interve ntions, by Eva Su.
12 For more on the discounted cash flow model and multiples analysis, see WallStreetPrep, “ Introduction to T he DCF
Model,” at https://www.wallstreetprep.com/knowledge/dcf-model-training-6-steps-building-dcf-model-excel; and
McKinsey & Company, “ T he Right Role for Multiples in Valuation,” March 2005, at https://www.mckinsey.com/
business-functions/strategy-and-corporate-finance/our-insights/the-right-role-for-multiples-in-valuation.
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seize up “financial plumbing,” as firms desperate for cash rush to liquidate stocks, further
distancing immediate stock prices from firms’ underlying valuations.
Figure 6. Office of Financial Research Financial Stress Index

Source: Office of Financial Research, U.S. Department of the Treasury, OFR Financial Stress Index, at
https://www.financialresearch.gov/financial-stress-index/.
Note: Shaded areas indicate U.S. recessions.
Selected Policy Responses
Congress and the SEC have responded to market volatility in several ways.
SEC Responses
The SEC has responsibilities regarding capital markets operations, systemic risk, and financial
stability. During the pandemic, its highlighted responsibilities include the following:13
 Market monitoring. Monitor market price movements and the availability and
flows of capital, and take related actions, including regulatory relief.
 Market function. Ensure the continuing, orderly, and fair function of the
securities markets for stocks, bonds, funds, and other products.
 Issuer disclosure. Facilitate timely and accurate disclosures of material
information to ensure market transparency.14
The SEC established a new cross-divisional COVID-19 market monitoring group in April 2020 to
analyze the effects of COVID-19 on capital markets.15 There are also many other new operational
and market monitoring initiatives. A summary of the SEC’s pandemic-related responses is
published through its SEC Coronavirus (COVID-19) Response web page.16

13 SEC Chairman Jay Clayton, “Remarks to the Financial Stability Oversight Council,” May 14, 2020, at
https://www.sec.gov/news/speech/clayton-remarks-financial-stability-oversight-council-051420.
14 For more details, see CRS In Focus IF11256, SEC Securities Disclosure: Background and Policy Issues, by Eva Su.
15 SEC, “SEC Forms Cross-Divisional COVID-19 Market Monitoring Group,” press release, April 24, 2020, at
https://www.sec.gov/news/press-release/2020-95.
16 SEC, “SEC Coronavirus (COVID-19) Response,” at https://www.sec.gov/sec-coronavirus-covid-19-response.
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Of special note are some of the SEC’s existing tools to help manage market volatility, including
circuit breakers and limit up-limit down (LULD) mechanisms. Circuit breakers are market-wide
temporary halts that occur at three single-day S&P 500 index decline thresholds—7% (level 1),
13% (level 2), and 20% (level 3).17 The level 1 and 2 circuit breakers general y enforce 15-
minute pauses, and the level 3 circuit breaker halts the market for the rest of the day.18 The
market-wide circuit breakers were triggered four times in March 2020, a relatively rare
occurrence (Figure 7). LULDs are single-stock halts enforced by “price bands” of 5%, 10%,
20%, or the lesser of $0.15 or 75%, depending on the stock price over the immediately preceding
five-minute trading period.19 A stock faces a five-minute trading pause if its price increases or
decreases outside of these price bands. Single-stock halts were triggered thousands of times in
March 2020 (Figure 8).
Figure 7. Incidence of Circuit Breakers
(number of times the S&P 500 fel 7% and hit a circuit breaker [as of April 2020])

Source: Deutsche Bank Research; Lev Borodovsky, “The Daily Shot: The Expected Spike in Savings Rate Wil
Hinder Recovery,” Wal Street Journal, April 23, 2020.

17 SEC, “Investor Bulletin: Measures to Address Market Volatility,” July 1, 2012, at https://www.sec.gov/oiea/investor-
alerts-bulletins/investor-alerts-circuitbreakersbulletinhtm.html.
18 A market decline that triggers a Level 1 or Level 2 circuit breaker before 3:25 p.m. will halt market -wide trading for
15 minutes, whereas a similar market decline at or after 3:25 p.m. will not halt market -wide trading.
19 SEC, “Investor Bulletin: Measures to Address Market Volatility,” July 1, 2012, at https://www.sec.gov/oiea/investor-
alerts-bulletins/investor-alerts-circuitbreakersbulletinhtm.html.
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Figure 8. Number of Unique Securities Triggering LULD Trading Pauses
(il ustrative examples of LULD trading pauses between 3/3/2020 and 3/13/2020)

Source: Bank of America Securities, Global Banking & Markets: Market Insights, at https://www.bofaml.com/en-us/
content/trader-insights/coronavirus-impact-market-structure-volatility.html.
Both market-wide and single-stock halts were designed to al ow investors to pause and digest
information during volatile and fast-paced market movements. While some believe the halts serve
the purpose of calming market volatility, others argue that the halts can be disruptive, especial y
when circuit breakers are tripped immediately following market openings.20 In addition to these
existing mechanisms, other proposals for potential agency responses to calm volatility include
banning short sales or revisiting the SEC’s uptick rule that applies short-sel ing restrictions.21
This is because short sales normal y involve investors sel ing borrowed stocks in the hope that
prices wil fal .22 Whereas some are concerned that short sales exacerbate market declines, others
believe the opposite is true because there is evidence of worse stock performance during short-
sel restrictions.23 Observers also argue that shutting down the stock market or opening it for a
shorter trading day may calm extreme market volatility. But views on this are also mixed, with
some observers believing total shutdowns are problematic.24

20 Alexander Osipovich and Dawn Lim, “Wall Street Explores Changes to Circuit Breakers After Coronavirus Crash,”
Wall Street Journal, April 15, 2020, at https://www.wsj.com/articles/wall-street -explores-changes-to-circuit-breakers-
after-coronavirus-crash-11586952558.
21 For more on the uptick rule, see SEC, “ SEC Approves Short Selling Restrictions,” press release, February 24, 2015,
at https://www.sec.gov/news/press/2010/2010-26.htm.
22 SEC, “Short Sales,” at https://www.sec.gov/answers/shortsale.htm.
23 Robert Battalio, Hamid Mehran, and Paul Schultz, “Market Declines: What Is Accomplished by Banning Short -
Selling?” Federal Reserve Bank New York, 2012, at https://www.newyorkfed.org/medialibrary/media/research/
current_issues/ci18-5.pdf.
24 Reuters, “U.S. Finance Industry Says Markets Must Stay Open During Pandemic,” March 20, 2020, at
https://www.reuters.com/article/us-health-coronavirus-usa-markets/u-s-finance-industry-says-markets-must-stay-open-
during-epidemic-idUSKBN21720O.
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The coronavirus pandemic has created operational chal enges for both capital markets and the
SEC. COVID-19-related risks and uncertainties could make it chal enging for publicly traded
companies to fulfil their obligations to file periodic financial disclosures and hold annual
shareholder meetings. For example, the pandemic could directly affect these companies’ normal
course of operations in relation to the filings process. It could also create chal enges for assessing
a company’s financial performance given COVID-19 related uncertainties. The SEC has provided
conditional regulatory relief for affected public companies’ filing obligations.25 It has also
provided guidance to encourage virtual annual meetings for shareholder engagements.26 The
agency has also issued a temporary coronavirus no-action letter and an exemptive order to
provide more rollout time for the Consolidated Audit Trail, a large multiyear data project.27 The
New York Stock Exchange temporarily closed its human trading floor and switched to fully
electronic operation to avoid contagion, and the SEC has published a related notice.28
Legislative Responses
The CARES Act (P.L. 116-136), enacted on March 27, provides both fiscal stimulus and liquidity
support to respond to the pandemic.29 The stock market initial y responded positively to the $2
tril ion (10% of GDP) in total direct relief in P.L. 116-136. Although much of it is not directly
aimed at capital markets, provisions in Division A, Title IV of P.L. 116-136 that may particularly
influence financial markets include al owing the Department of the Treasury to provide loans,
loan guarantees, and other backstops for businesses and Federal Reserve facilities;30 and
providing financial assistance to certain segments of the economy, conditioned upon government
equity stakes, executive compensation restrictions, and a ban on stock buybacks. Other broad
relief legislation with significant financial market provisions includes H.R. 6321, which proposes
to mandate securities disclosures on supply chain disruption and global pandemic risk and to
require the SEC to provide pandemic guidance, testing, and reporting.
Corporate Bonds
U.S. companies are carrying record levels of debt to finance their operations (Figure 9). A large
portion of the debt is in corporate bonds.31 Investors in corporate bonds are functioning as lenders

25 SEC, Order Under Section 36 of the Securities Exchange Act of 1934 Granting Exemptions from Specified
Provisions of the Exchange Act and Certain Rules Thereunder, at https://www.sec.gov/rules/other/2020/34-88318.pdf.
26 SEC, Staff Guidance for Conducting Shareholder Meetings in Light of COVID-19 Concerns, at https://www.sec.gov/
ocr/staff-guidance-conducting-annual-meetings-light-covid-19-concerns.
27 SEC, Update on Consolidated Audit Trail; Temporary COVID-19 Staff No-Action Letter; Reducing Cybersecurity
Risks, March 17, 2020, at https://www.sec.gov/news/public-statement/statement -clayton-cat-covid-19-nal-
cybersecurity-2020-03-17; and SEC, Order Granting Conditional Exem ptive Relief, Pursuant to Section 36 of the
Securities Exchange Act of 1934 (“Exchange Act”) and Rule 608(e) of Regulation NMS Under the Exchange Act, from
Sections 6.4, 6.7(a)(v) and 6.7(a)(vi) of the National Market System Plan Governing the Consol idated Audit Trail,
April 20, 2020, at https://www.sec.gov/rules/exorders/2020/34-88702.pdf.
28 SEC, Self-Regulatory Organizations; New York Stock Exchange LLC; Notice of Filing and Im mediate Effectiveness
of Proposed Rule Change to Am end Rules 7.35A, 7.35B, and 7.35C for a Tem porary Period , March 20, 2020, at
https://www.sec.gov/rules/sro/nyse/2020/34-88444.pdf.
29 For more details, see CRS Report R46301, Title IV Provisions of the CARES Act (P.L. 116-136), coordinated by
Andrew P. Scott .
30 For more details, see CRS Report R46329, Treasury and Federal Reserve Financial Assistance in Title IV of the
CARES Act (P.L. 116-136), coordinated by Andrew P. Scott .
31 T he corporate debt market also consists, to a much lesser extent, of leveraged loans, bank loans, and other liabilities.
For more on leveraged loans, see CRS Report R46096, Leveraged Lending and Collateralized Loan Obligations:
Frequently Asked Questions, by Eva Su, Marc Labonte, and David W. Perkins.
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who general y receive the payments of principal plus interest over a period of time. The bonds
themselves are financial instruments that can be bought or sold.
Figure 9. Corporate Debt as a Share of GDP

Source: Goldman Sachs, Assessing Credit Losses and Risks to the Banking System, May 25, 2020.
Note: Shaded areas indicate recessions.
Bond issuers’ borrowing costs and liquidity are general y determined by their credit ratings,
which are assigned by credit rating agencies. These ratings intend to indicate the issuers’
investment risks and payment capabilities. For example, bonds can receive either investment-
grade or high-yield (also cal ed below investment grade, speculative grade, or junk bond)
ratings—the higher the rating, the lower the borrowing costs (Table 1).32
Table 1. Corporate Bond Credit Ratings

Moody’s
Standard & Poor’s and Fitch
Investment Grade

Highest quality (best quality, smal est degree of investment risk)
Aaa
AAA
High quality (often cal ed high-grade bonds)
Aa
AA
Upper medium grade (many favorite investment attributes)
A
A
Medium grade (neither highly protected nor poorly secured)
Baa
BBB
High Yield (Speculative Grade)

Somewhat speculative (have speculative elements)
Ba
BB
Speculative (general y lack characteristics of a desirable
B
B
investment)
Highly speculative (bonds of poor standing)
Caa
CCC

32 PIMCO, “Corporate Bonds,” at https://www.pimco.com/en-us/resources/education/understanding-corporate-bonds.
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Moody’s
Standard & Poor’s and Fitch
Most speculative (poor prospects)
Ca
CC
Imminent default (extremely poor prospects)
C
C
Default
C
D
Source: PIMCO, Understanding Corporate Bonds, at https://www.pimco.com/en-us/resources/education/
understanding-corporate-bonds.
The “Seized Up” Corporate Debt Market
The coronavirus-induced market crash in March put the corporate debt market to a real-world
stress test, with the market’s main segments “seized up” and unable to provide normal operations.
Investment-grade bond funds experienced the largest outflow on record.33 High-yield bonds and
other high-risk asset prices have fal en sharply. Bond yields and prices move in opposite
directions—the higher the yields, the higher the borrowing costs, and the lower the bond prices.
Economic activities, especial y those in the hardest-hit segments (e.g., travel, retail, sports), have
nearly come to a stop.34 Affected businesses have begun to have difficulty generating earnings,35
which could reduce their ability to repay corporate debt and further restrict their ability to access
funding.
Investment-Grade BBB-Rated Bonds
Financial regulators have shown particular concern over the growth of BBB bonds—which, in
this report, refer to the lowest-quality investment-grade bonds (Figure 10 and Table 1). BBB
bonds made up around half of the investment-grade market as of 2019, compared to 17% in
2001.36

33 Claire Boston, Olivia Raimonde, and Alex Harris, “High-Grade Bond-Fund Outflows Hit $35.6 Billion, Smashing
Record,” Bloomberg, March 19, 2020, at https://www.bloomberg.com/news/articles/2020-03-19/investors-pull-record-
35-6-billion-from-investment-grade-debt.
34 T homas Gryta and Jennifer Maloney, “Sports, Retailors, and Airlines, Autos: T he Damage Across Business,” Wall
Street Journal, March 15, 2020, at https://www.wsj.com/articles/how-a-virus-upended-the-business-world-
11584150596.
35 For example, the restaurant and the airline industries were among the first t o experience difficulty generating
earnings. See Dean Donovan, “How the Airline Industry Will T ransform Itself as It Comes Back from Coronavirus,”
Forbes, March 30, 2020, at https://www.forbes.com/sites/deandonovan/2020/03/30/how-the-airline-industry-will-
transform-itself-as-it-comes-back-from-cornonavirus/#3e72600167b9.
36 Karen Schenone, “Making the Grade: How Risky Are BBB Bonds?” Nasdaq, October 7, 2019, at
https://www.nasdaq.com/articles/making-the-grade%3A-how-risky-are-bbb-bonds-2019-10-07.
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Figure 10. Changes in Corporate Bond Credit Rating Composition
(market capitalization of Bloomberg Barclays Corporate Indexes, BBB [Baa] growth highlighted in gray)

Source: Deutsche Bank Research; London Business School, Centre for Economic Policy Research COVID-19
Webinar, April 1, 2020, at https://www.forbes.com/sites/lbsbusinessstrategyreview/2020/04/01/centre-for-
economic-policy-research-covid-19-webinar/#70f5d10257f2.
BBB bonds draw concerns over “fal en angels” risk—the risk that further downgrades could push
a BBB bond’s rating from investment grade to high yield. This migration would adversely affect
companies’ borrowing capacity and costs, thus increasing the likelihood that these already risky
companies may default. Large-scale defaults might, in turn, lead to systemic risk and financial
stability concerns. The long-term average rate by which “angels fal ” is around 5% per year, with
higher rates seen during business downturns (Figure 11). Various credit strategists have projected
that the volume of fal en angels wil continue to increase substantial y in 2020, although the exact
projections differ (Table 2).37

37 Molly Smith, “ Virus Sell-Off T urns Bonds Into ‘Fallen Angels.’ Here’s Why Downgrades Matter,” Bloomberg,
April 1, 2020, at https://www.bloomberg.com/news/articles/2020-04-01/bond-downgrades-by-the-boatload-and-why-
they-matter-quicktake.
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Figure 11. Percentage of BBB-Rated Issuers That Become Fallen Angels Within a
Year

Source: Organisation for Economic Co-operation and Development, Corporate Bond Market Trends, Emerging
Risks and Monetary Policy, 2020, at http://www.oecd.org/corporate/ca/Corporate-Bond-Market-Trends-Emerging-
Risks-Monetary-Policy.pdf#page=47.
Table 2. Credit Strategists’ Estimations of 2020 Fallen Angels Volume
Credit Strategist
Fallen Angel Volume Estimate for 2020
UBS
$115 bil ion - $140 bil ion
Barclays
$175 bil ion - $200 bil ion
Bank of America
$200 bil ion
JPMorgan
$215 bil ion
Citigroup
$250 bil ion - $300 bil ion
Morgan Stanley
$300 bil ion - $350 bil ion
Source: Mol y Smith, “Virus Sel -Off Turns Bonds Into ‘Fal en Angels.’ Here’s Why Downgrades Matter,”
Bloomberg, April 1, 2020, at https://www.bloomberg.com/news/articles/2020-04-01/bond-downgrades-by-the-
boatload-and-why-they-matter-quicktake.
Some observers are also concerned that large volumes of fal en angels may place pressure on the
high-yield market.38 This is a concern because investment-grade and high-yield bonds have
different investor pools that convey different levels of investment capacity and liquidity, so the
high-yield market’s narrower investor pool may not be able to absorb large volumes of fal en
angels efficiently.
In addition, some analysts are concerned that forced sales by institutional investors, who are
required to hold only investment-grade bonds, could further distort the bonds’ prices and liquidity.
However, some academic research suggests that the actual liquidation pressure from forced sales
of fal en angels could be relatively smal .39

38 Organisation for Economic Co-operation and Development, Corporate Bond Markets in a Time of Unconventional
Monetary Policy, February 18, 2020, at http://www.oecd.org/corporate/Corporate-Bond-Markets-in-a-Time-of-
Unconventional-Monetary-Policy.htm.
39 Brent Ambrose, Nianyun Kai, and Jean Helwege, “ Forced Selling of Fallen Angels,” Journal of Fixed Income,
March 14, 2008, at http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.139.1160.
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High-Yield Bonds
High-yield bonds receive lower than BBB or equivalent ratings (Table 1). These bonds have a
higher rate of return accompanied by a higher risk of default, meaning that investors have a
greater chance of not receiving interest and principal at maturity.40 The U.S. high-yield market
size is around $1 tril ion and includes many companies from different industry sectors. Familiar
high-yield issuers include Netflix, Steak ’n Shake, and Delta Airlines. Although actual high-yield
bond default rates have not spiked as of April 2020, major rating agencies have projected their
default rates to multiply (Figure 12).
Figure 12. S&P High Yield Default Rate (Percent of Issuers)

Source: S&P Global Ratings; International Monetary Fund, Global Financial Stability Report: Markets in the Time of
COVID-19, April 2020, at https://www.imf.org/~/media/Files/Publications/GFSR/2020/April/English/ch1.ashx.
Selected Policy Responses
As previously discussed, policymakers have introduced market-wide actions and rescue packages
to calm volatility, including broad-scale federal government liquidity intervention. The ongoing
policy debate regarding credit rating agencies is also relevant, particularly as it closely relates to
corporate bonds’ pricing and liquidity.
Federal Government Liquidity Interventions
Policymakers are seeking ways to avoid permanent damages to sound corporate borrowers who
face what may be only a temporary period of low income during the coronavirus pandemic. The
Federal Reserve—sometimes with support from the Treasury Department—has established
several emergency lending facilities to provide liquidity to key capital markets segments.41 As of
this report’s publication, some markets that have announced Federal Reserve liquidity support
appear to have begun to stabilize. Figure 13 il ustrates the changing market conditions since the
Federal Reserve intervention.

40 SEC, “What Are High-Yield Corporate Bonds?” at https://www.sec.gov/files/ib_high-yield.pdf.
41 For more on Fed liquidity facilities, see CRS Insight IN11327, Federal Reserve: Emergency Lending in Response to
COVID-19, by Marc Labonte.
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Figure 13. Changing Market Conditions and Selected Federal Reserve
Announcement Dates
(vertical lines indicate selected announcement dates of Federal Reserve emergency interventions)

Source: Congressional Research Service based on S&P Capital IQ data.
Notes: For more details on related Federal Reserve emergency facilities, see Appendix B.
As previously discussed, a major portion of the corporate debt market is in higher-risk positions
than has been the case historical y.42 For example, BBB-rated bonds now make up a major portion
of the corporate bond market (Figure 10) and there is high growth in a type of risky corporate
debt cal ed leveraged loans.43 The concern in recent years has been that, during a market
downturn, funding costs and availability could change, driving already risky companies to
defaults and business closures. Furthermore, funding dislocation could drain out financial system
liquidity and amplify financial and economic vulnerabilities.
To keep capital markets functioning, the Federal Reserve (Fed) acted in March to provide broad
liquidity support for higher credit quality investment-grade issuers and bonds for the first time.
The bond market subsequently rebounded, but high-yield (noninvestment-grade) bonds, which
did not receive the announced support, stabilized less.
As the gap between the government-supported and nonsupported segments continued to widen in
March, issuers and investors began to crowd into the supported segments of the market. In March,
there were indications of high levels of new investment-grade bond issuance, but virtual y no new
high-yield bond issuance. The pricing gap between investment-grade and high-yield bonds had
also widened to several times the norm as of March, another sign of the difference between the
government-supported and nonsupported markets.
Furthermore, the pandemic-induced economic halt has generated downgrade pressure for many
companies. Of special concern are the lowest-quality investment-grade BBB bonds. Because the
Fed’s liquidity facilities were initial y limited to investment-grade issuers, a company’s loss of its

42 For more details, see CRS Insight IN11275, COVID-19 and Corporate Debt Market Stress, by Eva Su.
43 For more details on leveraged loans, see CRS Report R46096, Leveraged Lending and Collateralized Loan
Obligations: Frequently Asked Questions, by Eva Su, Marc Labonte, and David W. Perkins.
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investment-grade credit rating would have disqualified it from receiving support from those
facilities. A large number of fal en angels had already migrated into the high-yield category,
including some household names like Macy’s and Ford Motor.
Given the scale of the pressure, the Fed eventual y extended its liquidity facilities to fal en angels
by broadening the relief to include companies that lost investment-grade credit ratings after
March 22. Similarly, the Fed announced plans to further support the high-yield market by making
limited purchases of exchange-traded funds tracking high-yield corporate bonds.44 Following
these announcements, prices for high-yield bonds rose substantial y, possibly signaling the
restoration of the market to some extent. In addition, other fiscal packages and lending programs
that are not directly linked to the bond markets, but provide loans or cash assistance to bond
issuers, could ease the bond market’s funding pressure. For example, if bond issuers are eligible
for the Paycheck Protection Program and Main Street Lending Program, these bond issuers’
repayment capabilities and default rates could improve.45
Credit Rating Agency-Related Policy Debates
Credit rating agencies have been an area of ongoing policy concern since the 2007-2009 financial
crisis (see Appendix A for more details). Reacting specifical y to pandemic-induced downgrade
pressure, some observers suggest that rating agencies should stop assigning ratings for a few
months. These observers believe that, although rating agencies are technical y accurate in
downgrading companies due to pandemic-related earnings impairment, doing so during a
pandemic is not sensible.46
During the pandemic, rating agencies’ influence has been reduced because bond investors are no
longer tightly following the assigned credit ratings to price their trades. For example, high-yield
issuer Netflix was trading at investment-grade price levels in April, reflecting investors’ different
views about the issuer’s debt repayment capability.47 Conversely, a portion of investment-grade
BBB bonds’ prices moved prior to rating agencies’ downgrades to trade at high-yield levels,
further il ustrating the decoupling of actual bond pricing from credit ratings during the crisis.48
This decoupling reflects that some investors are forming their own judgements about a
company’s credit quality independent of the bond ratings. Credit ratings’ reduced influence
during the crisis could al eviate some policy concerns, because assuming some ratings are flawed,
investors at least are not placing blind faith in the credit rating agencies.
Funds
Investment funds are pooled investment vehicles that consolidate money from investors and
manage it for a fee. Public funds, such as mutual funds and exchange-traded funds, are broadly

44 For more on ET Fs, see CRS Report R45318, Exchange-Traded Funds (ETFs): Issues for Congress, by Eva Su.
45 For more on the Paycheck Protection Program, see CRS Insight IN11374, The Paycheck Protection Program (PPP)
and Larger Borrowers: Oversight Efforts and Options for Congress, by Sean Lowry; and Federal Reserve Board,
“Federal Reserve Board Announces It Is Expanding the Scope and Eligibility for the Main Street Lending Program,”
press release, April 30, 2020, at https://www.federalreserve.gov/newsevents/pressreleases/monetary20200430a.htm.
46 Matt Levine, “Money Stuff: Investors Want a Cure, Not a Winner,” Bloomberg, April 24, 2020, at
https://www.bloomberg.com/news/newsletters/2020-04-24/money-stuff-investors-want -a-cure-not-a-winner.
47 Molly Smith, “ Netflix to Borrow another $1 Billion with Record High Cash ,” Bloomberg, April 22, 2020, at
https://www.bloomberg.com/news/articles/2020-04-22/netflix-to-borrow-another-1-billion-with-cash-at-record-high.
48 Joe Rennison, “U.S. Investors Brace for Ratings Downgrades as T urmoil Deepens,” Financial Times, March 16,
2020, at https://www.ft.com/content/470cbfdc-6528-11ea-a6cd-df28cc3c6a68.
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accessible to investors of al types.49 Nearly half, or 44.8%, of al U.S. households own some
form of public fund.50 Mutual funds are the most widely used investment funds.51 They are also
cal ed open-ended funds, referring to their continuous offering of shares.
Mutual Fund Redemptions and Run Risk
When fund investors want to get their money back, they normal y redeem their mutual fund
shares or sel their ETF shares in open market trading. In a redemption, investors sel shares back
to the fund at per share net asset value (NAV), which equals the fund’s assets minus liabilities.
Many public funds, including mutual funds, may be susceptible to sudden large redemptions
(runs) if investors have an incentive to redeem shares before others do when there is a perception
that the fund could suffer a loss. Such requests can trigger run-risk concerns. Under normal
market conditions, fund managers balance the cash outflow for share redemption with cash inflow
from share purchases, prepayments, and asset maturity. Funds also have other liquid investments
set aside to meet redemption needs. But if a fund continuously experiences only outflow, or if the
size of the unanticipated redemption requests becomes too large, the fund would have to sel its
portfolio holdings to meet redemptions. These forced asset sel s may be executed at less than
optimal timing, potential y harming the fund’s returns. If this scenario occurred at a large scale,
these runs could destabilize the financial system. The run risk is more evident for funds that hold
less-liquid underlying portfolio assets.
Money market mutual funds (MMFs) in particular demonstrated during the 2007-2009 financial
crisis that they could experience runs and cause dislocation in funding markets. MMFs are a type
of mutual fund that invests in short-maturity, high credit-quality debt, such as Treasuries,
municipal bonds, commercial paper, and certificates of deposit. They are also common
investment options for households and businesses. On September 15, 2008, Lehman Brothers
Holdings Inc., an investment bank, filed for bankruptcy. The next day, one prominent MMF—the
Reserve Primary Fund—saw its per share price fal from $1.00 to $0.97 after writing off its
Lehman debt. This event triggered an array of market reactions, including investors’ redemptions
of more than $250 bil ion throughout the MMF industry within a few days of the bankruptcy. The
consequences of these actions were potential y so dire to U.S. financial stability that the
government ultimately intervened.52
During the pandemic-induced economic lockdown, many cash-strapped investors have
approached mutual funds and MMFs with redemption requests. In March 2020, as investors
rushed to make withdrawals, some mutual funds faced liquidity shortages and were under threat
to unload assets at a loss to meet redemptions.53

49 For more details on different types of funds and the asset management industry, see CRS Report R45957, Capital
Markets: Asset Managem ent and Related Policy Issues, by Eva Su.
50 Investment Company Institute, 2019 Investment Company Fact Book, at https://ici.org/pdf/2019_factbook.pdf.
51 For a comprehensive overview of fund types and the asset management industry, see CRS Report R45957, Capital
Markets: Asset Managem ent and Related Policy Issues, by Eva Su.
52 For more details, see CRS In Focus IF11320, Money Market Mutual Funds: A Financial Stability Case Study, by Eva
Su.
53 Dave Michaels, Justin Baer, and Paul Kiernan, “SEC Gives Relief to Mutual Funds Facing Redemption Issues,” Wall
Street Journal, March 24, 2020, at https://www.wsj.com/articles/sec-gives-relief-to-mutual-funds-facing-redemption-
issues-11585076903.
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Money Market Mutual Funds
The broader category of mutual funds holds around $21 tril ion in net assets.54 In general, mutual
funds are mostly comprised of longer-term investments that make up many households’
retirement portfolios. As a subset of the larger mutual fund world, MMFs hold more than $4
tril ion in net assets. Unlike many other mutual funds, MMFs are mainly used for short-term
investments and corporate financing.
The main types of MMFs are (1) prime, which include investments in corporate debt, certificates
of deposit, and repurchase agreements; (2) tax-exempt, also referred to as municipal, which invest
in national or state municipal securities that are free of national or state inc ome tax; and (3)
government and Treasury, which invest in securities backed by the creditworthiness of the U.S.
government. The main types of MMFs are then further divided into those held by individual
investors (retail) or those held by organizations (institutional).55 As Figure 14 il ustrates, in
March 2020, while the ultra-safe government and Treasury MMFs received large inflows from
investors seeking safety during the pandemic crisis, corporate and municipal MMFs lost 11% and
6% of their net assets within one month, respectively.56 These actions further escalated market
pressure and induced federal government liquidity interventions.
Figure 14. Money Market Mutual Fund Net Assets Changes in March 2020
(in $bil ions)

Source: SEC, Money Market Fund Statistics Form N-MFP Data, period ending March 2020 Filings Received through
April 13, 2020, at https://www.sec.gov/files/mmf-statistics-2020-03.pdf.
Exchange-Traded Funds
Exchange-traded funds (ETFs) are also pooled investment vehicles that gather and invest money
from a variety of investors. Unlike mutual funds, ETF shares can trade on securities exchanges
like a stock, thus technical y not facing the same type of redemption risks as mutual
funds. However, ETFs can face “liquidity mismatch,” in which ETF shares trade at different price
levels than the ETF’s underlying portfolio’s per share NAV (a fund’s assets minus liabilities). The

54 Investment Company Institute, 2020 Investment Company Fact Book, at https://ici.org/pdf/2020_factbook.pdf#page=
2.
55 SEC, “Money Market Funds,” at https://www.sec.gov/answers/mfmmkt.htm.
56 For more details, see SEC, Money Market Fund Statistics Form N-MFP Data, period ending March 2020 Filings
Received through April 13, 2020, at https://www.sec.gov/files/mmf-statistics-2020-03.pdf.
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effects of liquidity mismatch and ETF NAV gaps are a subject of long-term policy debate. Some
argue that ETF NAV gaps during market stress are evidence of ETF shares providing faster price
discovery than underlying bonds.57 Others are concerned the liquidity mismatch could pose a
threat to financial stability.58
Figure 15. Bond ETF NAV Gaps in March 2020
(investment-grade ETFs [left] and high-yield ETFs [right])

Source: Bank for International Settlements, The Recent Distress in Corporate Bond Markets: Cues from ETFs, April
14, 2020, at https://www.bis.org/publ/bisbul 06.pdf.
Note: Includes both U.S. and European ETFs.
During the high market volatility experienced in March 2020, large gaps opened up between ETF
shares and the NAV of their holdings in an unprecedented manner, an indication of stress (Figure
15).59 In this short period, certain large bond ETFs saw both their widest discounts and widest
premium to NAV since inception. An ETF gap with discount to NAV means that ETF shares are
worth less than their underlying holdings, a situation that would not occur under normal market
conditions.
Selected Policy Responses
As previously discussed, policymakers have introduced market-wide actions and rescue packages
to calm volatility. For the fund market in particular, direct policy responses include federal
government liquidity intervention and SEC temporary exemption of interfund lending.

57 Sirio Aramonte and Fernando Avalos, The Recent Stress in Corporate Bond Markets: Cues from ETFs, Bank for
International Settlements, BIS Bulletin no. 6, April 14, 2020, at https://www.bis.org/publ/bisbull06.pdf. For more on
the definition of price discovery, see James Chen, “Price Discovery,” Investopedia, April 30, 2019, at
https://www.investopedia.com/terms/p/pricediscovery.asp.
58 For more on the liquidity mismatch-related policy debates, see CRS Report R45318, Exchange-Traded Funds
(ETFs): Issues for Congress, by Eva Su, p. 13.
59 Sirio Aramonte and Fernando Avalos, The Recent Stress in Corporate Bond Markets: Cues from ETFs.
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Federal Government Liquidity Support
For the MMF market, rather than waiting for signs of the situation becoming critical, on March
18, 2020, the Fed created an MMF liquidity facility based on a facility it had deployed during the
2007-2009 financial crisis. This facility would extend nonrecourse loans to banks and other
eligible financial institutions to purchase certain types of assets from MMFs. After this
announcement, MMFs have seen waves of inflows, which indicates that the Fed’s interventions
may have smoothed conditions in certain short-term credit markets.
For bond ETFs, on March 23, 2020, the Fed established a Secondary Market Corporate Credit
Facility that can buy certain ETFs that provide broad exposure to investment-grade bonds.60 The
Fed expanded the program on April 9, 2020, to include certain high-yield bond ETFs as wel .61
Before any actual purchases took place, the ETF market already showed signs of stabilization.
Bond ETFs experienced strong inflows immediately following the announcement, and some
ETFs reportedly ceased trading at discounts to their NAV.62
SEC Temporary Exemption of Interfund Lending
The SEC used a different approach to enhance fund liquidity. On March 23, 2020, it temporarily
relaxed interfund lending rules for certain funds to expand liquidity and ease their redemption
pressure.63 The SEC provided exemptions for registered open-end management investment
companies (excluding MMFs) and certain insurance company separate accounts. This type of
borrowing is normal y restricted. These temporary exemptions provide more sources of liquidity
from the funds’ affiliates. For example, individual mutual funds under redemption pressure can
borrow from their parent companies, which often manage a family of different funds, to ease
liquidity pressure.
The interfund lending exemption is temporary, rather than permanent, because it has advantages
as wel as drawbacks. Some academics argue that interfund lending might increase investments in
il iquid assets; reduce fund investors’ run-like behavior; and mitigate asset fire sales after extreme
investor redemptions.64 But other academics point out that interfund lending might transfer risks
from riskier funds to safer funds and create conflicts of interest concerns.65 Such “cross-fund
subsidization” can lead fund managers to enhance the safety and return of higher-risk funds at the
expense of lower-risk and lower-return funds.66

60 Federal Reserve Board, “ Federal Reserve Announces Extensive New Measures to Support the Economy ,” press
release, March 23, 2020, at https://www.federalreserve.gov/newsevents/pressreleases/monetary20200323b.htm.
61 Federal Reserve Board, Secondary Market Corporate Credit Facility Term Sheet, April 9, 2020, at
https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a2.pdf.
62 Katherine Greifeld, “ Fed’s Ability to Buy ET Fs May Help Ensure It Never Needs T o ,” Bloomberg, April 15, 2020,
at https://www.bloomberg.com/news/articles/2020-04-15/fed-didn-t-actually-have-to-buy-anything-to-rescue-bond-
etfs.
63 SEC, “SEC Provides T emporary Additional Flexibility to Registered Investment Companies Affected by
Coronavirus,” press release, March 23, 2020, at https://www.sec.gov/news/press-release/2020-70.
64 Vikas Agarwal and Haibei Zhao, “Interfund Lending in Mutual Fund Families: Role in Liquidity Management,” The
Review of Financial Studies, vol. 32, no. 10, October 2019, at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=
2644605.
65 Lewis Braham, “When Funds Lend to Each Other,” Barron’s, November 11, 2017, at https://www.barrons.com/
articles/when-funds-lend-to-one-another-1510369094.
66 Jose-Miguel Gaspar, Massimo Massa, and Pedro Matos, Favoritism in Mutual Fund Families? Evidence on Strategic
Cross-Fund Subsidization, March 2004, at SSRN: https://ssrn.com/abstract=557078.
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Conclusion
Periods of abnormal y high capital markets volatility have occurred throughout financial history.
The uncertainties that have triggered such events have ranged widely, from pandemics to
financial system breakdowns to geopolitical risks. Despite the different causes, levels of policy
actions in response have largely depended on the size of the harm and how widely risks have
spread. In some situations, risks built up in expected patterns, and outcomes under stress were not
much of a surprise, no matter what the triggering event was. In other situations, heightened stress
revealed unexpected areas of vulnerability, and unprecedented policy solutions were needed to
address them. In the case of the COVID-19-induced capital markets selloffs, market dislocations
have been broadly felt, and the policy response has included some expected actions and uses of
existing tools, as wel as new developments and new policy solutions. Despite the signs that these
policy actions have stabilized the markets to an extent, uncertainties surrounding the pandemic
continue to pose threats to capital markets. If the threats unfold, capital markets conditions could
change rapidly. Given the chal enges of controlling the pandemic, how and when the COVID-19
crisis could end wil decide the parameters for further policy responses.
Capital Markets and COVID-19 Product Series
CRS Insight IN11421, Leveraged Loans and Collateralized Loan Obligations (CLOs): Recent
Developments and Policy Actions, by Eva Su.
CRS Insight IN11309, COVID-19 and Stock Market Stress, by Eva Su.
CRS Insight IN11275, COVID-19 and Corporate Debt Market Stress, by Eva Su.
CRS Insight IN11339, Securities and Exchange Commission (SEC) Actions to Mitigate the
Impact of COVID-19, by Gary Shorter.
CRS In Focus IF11320, Money Market Mutual Funds: A Financial Stability Case Study, by Eva
Su.

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Appendix A. Credit Rating Agency-Related Policy
Debates
Credit rating agencies have been an area of ongoing policy concern since the 2007-2009 financial
crisis. Some argue that credit rating agencies could potential y inflate credit ratings to make it
easier for corporations to borrow, which could harm corporate debt investors. Observers recal the
2007-2009 financial crisis, when credit rating agencies al egedly inappropriately assigned high
ratings to risky securities, misled investors, and amplified the financial crisis. As a result, the
rating agencies paid bil ion-dollar settlements and received tightened regulation.67 But a decade
later, the industry’s high concentration and “issuer pays” business model, which are the main
sources of criticism, remain largely unchanged.
Rating inflation, market concentration, and conflicts of interest are key elements of policy
discussions about the rating agencies. The three largest rating agencies—S&P, Moody’s, and
Fitch—account for 95% of al outstanding credit ratings (Figure A-1).68 These rating agencies are
general y paid by the bond issuers to which they assign ratings, referred to as an “issuer pays”
business model. Some believe this business model incentivizes the agencies to provide higher
credit ratings in exchange for revenue and market share.69 Smal er rating agencies do exist, but a
recent analysis suggests that they are fueling, instead of reducing, potential rate inflation