An industry advocacy organization, the Structured Finance Industry Group (http://www.sfindustry.org/) comments to the SEC in its letter on proposed MMF reforms, "We are concerned that the broad nature of some of the proposed amendments may restrict the amount of asset-backed securities ("ABS") available for purchase by money market funds. The proposals would in particular affect asset-backed commercial paper ("ABCP"). ABCP is a form of ABS issued by a special purpose entity (an "ABCP conduit") that is frequently sold to money market funds. ABCP is an important source of funding to the real economy, providing substantial funding of trade receivables, auto loan and lease receivables, equipment loans and leases, student loans and credit card and consumer loan receivables and other corporate and consumer financial assets. As of July 31, 2013, money market funds held over $94 billion [source: Crane Data] of ABCP representing approximately 36% of the overall ABCP market. The comments provided herein are intended to highlight the concerns of our members regarding these enhanced diversification proposals. We understand that the scope of the Release is far-reaching, however, we express no views about any of the proposed amendments other than those discussed in this letter.... We recommend that the SEC's final rules specifically exclude equity owners of ABCP conduits from the new affiliate aggregation rule, allowing funds to treat each special-purpose entity ("SPE") issuing ABS as a separate issuer for purposes of issuer diversification testing even if the same entity or affiliate group controls the voting equity of multiple ABCP conduits."
