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abil ability to manage through and mitigate potential contagion from high levels of redemptions Imposing transparency
accept acceptance for any sort of VNAV MMF and the record established by the Commission is insufficient
achiev achieved through causing investors to experience price changes as the Commission asserts. Transparency is achieved
act Act of 1940 the 1940 Act and approximately 24 billion in two offshore dollar denominated
activ activity Increasing MMFs ability to manage through and mitigate potential contagion from high levels of redemptions
add adds Dreyfus welcomes the Commission s intent to preserve the intrinsic value of MMFs in its proposals
address address the perceived structural vulnerabilities of MMFs. Instead we think these are complementary and not discrete
addresse address the perceived structural vulnerabilities of MMFs. Instead we think these are complementary and not discrete
adds adds Dreyfus welcomes the Commission s intent to preserve the intrinsic value of MMFs in its proposals
adequ adequately address the perceived first mover advantage and should not be expected to reduce portfolio
adopt adopted . Cardona also writes Dreyfus also continues to believe that too much emphasis has been
adopted adopted . Cardona also writes Dreyfus also continues to believe that too much emphasis has been
advantag advantage and should not be expected to reduce portfolio or systemic stress during times market
aim aims we believe a number of the Proposals are not appropriately designed to achieve the Policy
allow allow for certain funds to maintain a CNAV . We can see how these Proposals to some
alon alone alternative . We believe Fees and Gates directly answer the perceived structural vulnerabilities of MMFs
also also writes Dreyfus also continues to believe that too much emphasis has been placed on stopping
altern alternatives particularly without appropriate tax relief as we discuss in Section Ill below despite the proposed
among among the proposals not one size fits all and that a requisite balance must be achieved
amort amortized cost as a means for valuing the portfolio securities with remaining maturities of 60 days
anoth another major comment letter on the SEC s recent Money Market Fund Reform Proposal www.sec.gov
answer answer the perceived structural vulnerabilities of MMFs and the Policy Goals and should be given
appreci appreciates the opportunity to respond to the Money Market Fund Reform proposals the Proposals recently
approach approach can successfully mitigate systemic risk by broadly enhancing MMFs resiliency. Importantly we do not think
appropri appropriately designed to achieve the Policy Goals and are more likely to diminish rather than
approxim approximately 260 billion in assets including approximately 167 billion in 41 domestic money market mutual
assert assertions made in the Release a VNAV structure eliminates the fund s ability to serve
assess assess how a fund can be expected to perform in various market conditions. These are threshold
asset assets including approximately 167 billion in 41 domestic money market mutual fund MMF portfolios that
associ associated with their MMF investment . The VNAV structure fails to adequately address the perceived first
avail available for investors to assess how a fund can be expected to perform in various
back back to the well again today and cite yet another major comment letter on the SEC s recent
balanc balance must be achieved between preserving the unique value of MMFs for all investors both
bank Bank of New York Mellon Corporation a global financial services company operating in 36 countries
bank Bank of New York Mellon Corporation a global financial services company operating in 36 countries
believ believe a number of the Proposals are not appropriately designed to achieve the Policy Goals
benchmarks
best best chance for the Commission to achieve its Policy Goal of preserving the utility of MMFs
billion billion in assets including approximately 167 billion in 41 domestic money market mutual fund MMF portfolios