Another Comment Letter has been posted to the SEC's "President's Working Group Report on Money Market Fund Reform" page. Karrie McMillan, General Counsel of the Investment Company Institute, writes, "The Investment Company Institute is pleased to offer the following submission for consideration by the Securities and Exchange Commission as it contemplates whether any additional regulation of money market funds is appropriate. Money market funds -- which seek to offer investors liquidity, a market-based rate of return, and stability of principal, all at a reasonable cost -- serve as an effective cash management tool for investors, and as an indispensable source of short-term financing for the global economy. Given the importance of these funds, ICI and its members have devoted significant time and resources to strengthening the regulation of money market funds and making them more robust under adverse market conditions. To this end, on February 7, 2012, we submitted the attached submission as a resource to the International Organization of Securities Commissions' Standing Committee on Investment Management as it examines money market funds, particularly the U.S. money market fund industry. The submission begins with an overview of the U.S. money market (Section I). Next, it describes the regulation of U.S. money market funds, including the SEC's recent reforms and how the funds weathered their first 'stress test' since those reforms (Section II). Finally, the submission examines each of the reform options currently under serious consideration in the United States and describes how they would undermine money market funds' value to investors, effectively destroying these funds and disrupting the supply of credit to businesses, states and local governments, and consumers (Section III)."
