August 14, 2012
Chairman Schapiro
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Dear Chairman Schapiro:
Chairman Schapiro and Mr Sperling,
As an investor for 20 years, I find the misinformation and misguided proposals regarding money market funds disturbing. I invest for both my retirement and my 3 year old daughters education.
I have both and undergraduate degree in economics and an MBA in Finance.
I understand what money funds can and cannot invest in. My investment portfolio utilizes money funds for both liquidity and short term investment needs.
A few comments on the proposals.
Floating NAV.
This is an accounting nightmare and as the test case of reporting "shadow NAVs " for a number of quarters illustrates, most are rounding down to 1.00
Redemption hold back
This is not acceptable. How can I buy a investment in my account when I can only have part of my money to pay for it? The alternative is to put it in a bank and earn no interest, but still have to wait at least a day to wire in money!
Capital Buffers
Take a look at the firms that seem to have the biggest problems. They had a problem because they knew that their parent would bail them out. This leads to more risk, not less. The worst offender Citibank with its Legg Mason unit and SIV's . I never buy banks proprietary money funds because they are loaded with paper created by the bank that the marketplace would
not buy.
Summary
These proposed changes are not helpful to investors and have the potential to make the largest banks in this country even more dangerous to our economy.
Sincerely,
Vincent Morrow