SIFMA Comments on SEC MMF Proposal

SIFMA submitted comments to the SEC regarding the SEC proposed changes to reform the way money market funds ("MMFs") operate. In the comment letter, SIFMA stated their support of the SEC goals to enhance the resiliency of MMFs. However, SIFMA voiced concerns that some elements of the SEC proposal would alter certain indispensable characteristics of MMFs that make them attractive to shareholders, thereby endangering the viability of MMFs as an investment option and vital element of capital formation and credit availability. SIFMA urged the SEC not to impose both the floating net asset value ("NAV") and the liquidity fee and redemption gate proposals together on any type of MMF, among other recommendations and comments.

See: SIFMA Press Release; SIFMA Comment Letter. See also: Committee on Financial Services to Examine SEC's Money Market Fund Rule Proposal (September 16, 2013); SEC Proposes in the Federal Register Money Market Fund Reform and Amendments to Form PF; Comments Due September 17th (with Lofchie Comment) (June 19, 2013); SEC Proposes Money Market Fund Reforms (June 6, 2013); SEC Open Meeting: Money Market Fund Reform (with link to Delta Strategy Description of SEC Meeting) (June 5, 2013).