SIFMA Comments on MMF Reforms
A letter from Timothy W. Cameron, Managing Director, SIFMA Asset Management Group says, "The Securities Industry and Financial Markets Association (“SIFMA”) respectfully submits these comments on the proposed new and amended rules and forms relating to money market funds in the Release (the "Proposed Rules"). This letter has been prepared by the Asset Management Group of SIFMA and the Private Client Group of SIFMA, working together with SIFMA's Municipal Securities, Operations and Technology, Accounting and Taxation divisions. We appreciate the opportunity to provide our views to the Securities and Exchange Commission.... As an initial matter, we express our support for the Commission as it fulfills its role as the primary regulator of money market funds. In November 2012, the Financial Stability Oversight Council (FSOC) issued proposed recommendations to the Commission for reform of money market funds. These proposals were premature and potentially unhelpful, given the Commission's continuing exploration of money market fund reform. We continue to believe strongly, as set forth in our prior comments to FSOC in January 2013, that FSOC and its members should refrain from making recommendations to the Commission on money market fund reform while the Commission is fully engaged on the issue.... While we support the Commission's goals, we are very concerned that certain of the proposed reforms would either obstruct the operation of money market funds or alter their indispensable characteristics, harming shareholders who rely on them as a cash management tool and issuers who depend on money market funds as an important source of financing. Below we identify potentially harmful aspects of the reforms and recommend several modifications with the goal of better focusing the Proposed Rules towards strengthening the resilience of money market funds in the face of systemic pressures."
