Corporate treasurers' organization, the Association for Financial Professionals commented recently to FSOC, "AFP fully supports amending the current rules in a manner that encourages clear and concise transparency, not only protecting investors but providing them with the necessary information needed to make the most sound and practical investment decisions for their organizations. AFP maintains that the implementation of additional regulation on MMFs, in the form of the recommendations presented by FSOC, will have major unintended harmful consequences that will result in significantly reduced investor interest in this investment. We urge the FSOC to consider the potential impact any changes to MMF rules may have on how investors in MMFs must account for investments under generally accepted accounting principles (GAAP). Specifically, while MMFs can currently be included as cash and cash equivalents due to their fixed share price and daily liquidity, the proposed rules may prohibit MMFs from being included as cash and cash equivalents and instead require that they be treated as short-term investments. Such a change would create complex and burdensome administrative expenses and potentially threaten compliance with debt covenants that mandate certain levels of cash equivalents."

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