NH Senators Comment to SEC
Entries to the SEC's "Comments on Proposed Rule: Money Market Fund Reform; Amendments to Form PF" website continue to trickle in. The latest, labeled "Senator Jeanne Shaheen, et al., Congress of the United States," comes from the New Hampshire Congressional delegation (signed by Senators `Jeanne Shaheen and Kelly Ayotte, and Congresswomen Carol Shea-Porter and Anne McLane Kuster). It says, "We write as representatives of the State of New Hampshire to express our concern over the current proposal put forth by the Securities and Exchange Commission (SEC) to impose new regulations on money market mutual funds, particularly municipal funds that are critical to state and local governments. We believe strongly in the SEC's mission to protect investors and ensure that our capital markets are fair and efficient for all Americans. We recognize the SEC has been committed to money market fund reform since the financial crisis, and we appreciate its diligence in pursuing reforms to make the product more transparent and resilient. However, we have serious concerns that the proposal will unnecessarily harm municipal money market funds. The proposal appropriately excludes Treasury and Government money market funds, which remained stable during the period following the bankruptcy of Lehman Brothers in 2008. Similarly, municipal money market funds did not experience large redemptions during the crisis and should also be excluded from the proposal. Applying either a floating net asset value (NAV) or investor redemption restriction to municipal funds is not appropriate and would dramatically reduce investment in these funds, thereby increasing borrowing costs for the already-strapped state and local governments that depend on money market funds to meet important financing needs. Like Treasury and Government money market funds, municipal funds do not invest in the same types of corporate debt securities in which prime funds invest. As you know, during the financial crisis, prime money market funds held by large institutional investors were the only funds that experienced significant and rapid investor withdrawals."
