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The Mutual Fund Directors Forum
is the latest to file a Comment on the FSOC's "Proposed Recommendations Regarding Money Market Mutual Fund Reform"
. The independent fund directors' organization
writes, "The Commission has not abdicated its responsibilities with respect to money market funds
. Although the Commission did not take additional action in 2012, the Commission did adopt significant amendments to the regulations governing money market funds in 2010 and continues actively to analyze the impact of these amendments, both on the risks posed by individual funds and on the nature of the risk that these funds pose to the broader financial system. Moreover, recent comments and actions by individual Commissioners demonstrate that the Commission is continuing to work with the industry and internally to identify and analyze varying approaches to the regulation of money market funds
. Indeed, regulatory approaches not fully addressed in the Proposed Recommendations, such as the use of liquidity fees, are now being actively discussed in the industry..... [
e very much appreciate the opportunity to comment on the Council'
s Proposed Recommendations on behalf of our independent director members. As our comments, and the likely comments of many other industry participants demonstrate, while money market funds play a key role in our financial markets and provide investors an important competitive option for managing their cash and liquidity needs, the extent to which money market funds pose a real systemic risk to the financial system remains unclear
. Many recent studies, including the SEC staff'
s recent report, are positive first steps in attempting to answer this question. We therefore urge the Council and other regulators to continue to analyze these questions before imposing costly new regulations on the money market fund industry that will render these funds a less competitive, less compelling option for their investors
." Note: Comments to FSOC are due by this Friday, February 15