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abcp ABCP Finally the transition period for these changes is given as 6 months. This will
abolit abolition of CNAV funds leading to fewer choices for investors . The proposals conflict with three
accept accepted by the FASB as compliant with GAAP . The prohibition of amortised cost accounting will
account accounting techniques is unjustified . The release explains IMMFA does not believe that requiring a 3 capital
achiev achieving little in terms of the stated aims . These would Removal of fund ratings problematic
add add Beyond these fundamental issues there are numerous other prescribed changes which would make the continued
addit additional regulation that will strengthen money market funds in the European Union and protect their
address address at our upcoming European Money Fund Symposium www.euromfs.com which will take place Sept. 24 25 in Dublin
addresse address at our upcoming European Money Fund Symposium www.euromfs.com which will take place Sept. 24 25 in Dublin
adds add Beyond these fundamental issues there are numerous other prescribed changes which would make the continued
afford affordable its imposition would require European domiciled CNAV MMF to raise E14bn E10bn by banks
aim aimed at shadow banking concerns. The EC has not demonstrated that CNAV funds are more
alreadi already rejected . Both the European Systemic Risk Board and the U.S. Securities and Exchange Commission
analysi analysis process Restriction on eligible assets specifically the restrictions on ABCP Finally the transition period
appar apparently achieving little in terms of the stated aims . These would Removal of fund ratings
append appended below for new regulatory measures aimed at shadow banking concerns. The EC has not demonstrated
arbitrag arbitrage opportunities will be created. There are no material differences between the money markets in US and the EC to justify
assert assertion that there is a greater degree of systemic risk inherent in constant NAV money
asset asset manager to hold 3 capital against a MMF. Even assuming that a 3 capital
associ Association IMMFA www.immfa.org the trade group that represents triple A rated stable value U.S. style
assum assuming that a 3 capital buffer were affordable its imposition would require European domiciled CNAV
awards
bank banks and E4bn by independent asset managers. Assuming banks are currently levered x20 x25 reassigning
bank banks and E4bn by independent asset managers. Assuming banks are currently levered x20 x25 reassigning
baron Barone Secretary General of IMMFA comments Some of the measures in today s EC proposal
base based Institutional Money Market Funds Association IMMFA www.immfa.org the trade group that represents triple A rated
basi basis damaging the value money market funds have for investors and therefore the value the funds
basic basic standards for rulemaking . They add In particular it s troubling that the proposal would
believ believe that requiring a 3 capital buffer for CNAV MMF will enhance systemic stability . Holding
benchmarks
benefit benefits these funds provide. The 3 percent capital NAV buffer is simply economically infeasible operationally
beyond Beyond these fundamental issues there are numerous other prescribed changes which would make the continued
blast posals The London based Institutional Money Market Funds Association IMMFA www.immfa.org the trade group that
board Board and the U.S. Securities and Exchange Commission have cited concerns about the ongoing cost
bodi bodies have already rejected . Both the European Systemic Risk Board and the U.S. Securities and Exchange
border border arbitrage opportunities will be created. There are no material differences between the money markets
broader broader economy. Finally they add Beyond these fundamental issues there are numerous other prescribed changes
brokerage
buffer buffer for CNAV MMF will enhance systemic stability . Holding capital is inappropriate for investment funds