PWG Comment from AFP, et. al.
Another Comment Letter on the President's Working Group Report on Money Market Fund Reform was posted late last week. This one, from Association for Financial Professionals, Benefit Resource, Inc. Blue Cross Blue Shield of Massachusetts, CacheMatrix, Catholic Health Initiatives, California ISO, CareSource, Centerline Capital Group, Crawford & Company, Grass Valley USA LLC, Miami-Dade County Public Schools, Solix, Inc., University of Colorado – Treasurer's Office, and WellCare Health Plans, Inc., says, "On behalf of the Association for Financial Professionals (AFP) and the undersigned companies, we are writing to provide and members of the Commission with our thoughts on an option currently being discussed relating to money market reforms. Our group of corporate treasurers and financial professionals fully support amending the current rules governing money market funds (MMFs) in a manner that encourages clear and concise transparency that not only protects investors, but provides them with the necessary information needed to make the most sound and practical investment decisions for their organizations. As such, we have concerns regarding one option to eliminate the stable net asset value (NAV) in favor of a floating NAV. The signees of this letter represent a broad spectrum of financial disciplines, and their organizations represent a wide variety of industries.... Our group recognizes that concerns about the liquidity of MMFs played a role in exacerbating the financial crisis that began in September 2008. As a result, we are largely supportive of rules already enacted by the Securities and Exchange Commission (SEC) to improve the liquidity and transparency of MMFs. The impact of many of these rules, including the monthly reporting of each fund's shadow NAV, has not yet been fully felt in the market. We believe that these new rules instituted significant changes that will, on their own, substantially reduce the liquidity concerns and systemic risks posed by MMFs. We oppose the proposal to eliminate the stable NAV in favor of a floating NAV, as we believe it would greatly reduce investors' interest in utilizing MMFs as a cash management and investment tool, whether applied to all investors or just institutional investors. For purchasers of MMFs, the return of principal is a much greater driver of the investment decision than return on principal. For a large number of institutional investors, the potential of principal loss would preclude investing in floating NAV MMFs."
