A recent SEC comment letter from David Hirschmann, CEO, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce says, "While the debate over additional money market fund regulation has continued among financial regulators despite the Commission's extensive amendments to Rule 2a-7 in 2010, CCMC believes that this rulemaking is an opportunity for the Commission to take a well-balanced and data-driven approach to strengthen MMFs and preserve the critical role they serve for U.S. businesses, state and local governments and for the economy as a whole. Failure to do so will impose significant costs and inefficiencies upon U.S. businesses, and the SEC will fail to fulfill its legal mandate to promote efficiency, competition and capital formation.... If the Commission's goal is to preserve the viability of MMFs while addressing the risk of heavy redemptions during times of severe market stress, for the reasons we explain below, we believe that the Proposal's Alternative 1, the floating net asset value, does not advance this goal. Indeed, CCMC is greatly concerned that certain regulatory changes described in the Proposal would seriously degrade the benefits of money market funds for U.S. businesses and that the predictable dislocations that would follow from these changes would impose substantial costs on job growth and the U.S. economy generally, in terms of less efficient cash management, less competition in markets for cash management and short-term financing, and higher costs of day-to-day financing for U.S. corporations. CCMC believes that these economic consequences are reasonably quantifiable. The adverse effects that Alternative 1 would have on competition, efficiency, and capital formation are discussed in detail in the accompanying report."

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