Attorney Melanie Fein posted another diatribe recently on the SEC's President's Working Group Comment Page. This one, entitled, "How Can The Risk of Runs on Money Market Funds Be Reduced?," says, "The question "how can the risk of runs on money market funds be reduced?" assumes that money market funds are susceptible to runs. There is little evidence to support such an assumption. In the entire history of money market funds ("MMFs") in the United States, only one "run" on MMFs ever has occurred in which in a MMF broke a dollar. That run occurred during the week of September 15, 2008 amid an unprecedented breakdown of the entire financial system triggered by the Federal Reserve's unexpected failure to rescue Lehman Brothers and a loss of confidence that the government had a coherent strategy for averting a financial disaster. The Federal Reserve had all but declared that it would not allow a systemically important institution to fail, but then did just that with Lehman, sending the financial markets into a tailspin. Even so, only one MMF "broke a dollar" in the resulting tumult. That fund's shareholders ultimately got back 99 cents on the dollar."

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