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More Comments Posted on SEC Proposed Broker Dealer 15c3-3 Rules. Though the comment period ended Tuesday, a number of last minute responses to the SEC's Proposed "Amendments to Financial Responsibility Rules for Broker-Dealers" have just been posted. The letters, all of which support the SEC's proposal to allow money funds for broker reserve deposit requirements, urge the Commission to allow all money funds, money funds which invest in "first tier" securities only, or AAA money funds. They also argue that the proposed "haircut" applied to money funds be reduced to zero instead of one percent. Just-posted response letters include: American Beacon's Mike Fields, Barclays' David Lonergan, BBH's Frank Perrone, and lawyers from BlackRock, ICI, UBS, and surprisingly strong support from the U.S. Chamber of Commerce. ICI's letter also footnotes the introduction of H.R. 1171 in Congress, the "Money Market Fund Parity Act of 2007", to direct the SEC to expand the use of money funds.
