Their comment letter says, "The Dreyfus Corporation welcomes the opportunity to comment on the money market fund reform options discussed in the '​Report of the President'​s Working Group on Financial Markets'. Dreyfus manages approximately $​405 billion in assets, including approximately $​287 billion invested in over 190 investment company portfolios, of which approximately $​205 billion is invested in 49 domestic money market mutual funds structured within the confines of Rule 2a-​7 under the Investment Company Act of 1940.... We commend the PWG'​s fair and balanced consideration of the potential for each Policy Option to reduce money market funds' susceptibility to runs. We were particularly pleased that the PWG was guided by a concern for mitigating possible adverse consequences of further regulatory change, such as the potential flight of assets from money market funds to less regulated or unregulated vehicles, and that the PWG recognized potentially effective Policy Options for reducing systemic risk without requiring the extreme act of transitioning to a floating net asset value for money market funds.... We believe first and foremost that it is unnecessary to obsolete Rule 2a-​7, stable NAV money market funds in order to reduce systemic risk. Accordingly, we do not support the Policy Option of adopting a floating NAV for money market funds.... Among the other Policy Options discussed in the Report, we believe a private emergency liquidity facility is the one Policy Option that would effectively reduce money market funds' susceptibility to runs and enhance their ability to withstand runs.... We believe the remaining Policy Options, some of which pose potential adverse consequences, ultimately would be unsuccessful in mitigating systemic risk, particularly during a liquidity crisis."

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