A recent SEC Comment Letter comes from Chris Barnard, Germany. The well-​versed apparently individual writes, "In general I would not support a floating NAV approach for the reasons outlined in my FSOC comment letter: that MMF investors are sophisticated and are aware of the nature of MMFs, and that they are not "​guaranteed"; and that maintaining a stable NAV is one of the key attractions of MMFs. However, I would be more inclined to support the floating NAV approach for prime institutional MMFs only, as these invest predominantly in corporate paper with its higher credit risk and interest rate volatility compared with the investments backing Government MMFs, and higher shareholder redemptions compared with Retail MMFs. Of the two proposed alternatives, the second alternative that introduces liquidity fees and redemption gates would be more practicable and operationally easier to implement. It would also more directly mitigate the risks of runs on MMFs in times of market stress. For these reasons I would support alternative two over alternative one, as this would provide greater benefits at lower cost compared with alternative one."

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