August 15, 2012
U.S. Securities and Exchange Commission
Dear Chairman Schapiro:
As a professional advisor working to help families achieve their financial goals, I wish to go on record as strongly opposed to the proposals under consideration at the Securities and Exchange Commission to change the fundamental nature of money market funds (MMFs), including proposals that would force MMFs to abandon their stable $1.00 per-share price and proposals to impose both unrealistic capital buffers and redemption freezes that would deny investors full access to their cash when they need it.
Investors value money market funds for the liquidity and convenience they provide in saving, managing cash, and maintaining flexible investment strategies. The stable share price and ability to access 100 percent of an investor's cash are key features of these funds. Removing either of these features would destroy MMFs' value to investors, eliminate MMFs' utility for sweep accounts and retirement plans, and damage funds' ability to offer such popular services as check writing and ATM access.
Changing the fundamental nature of money market funds will deprive my clients of the only product that provides current money-market yields within a diversified, fully transparent portfolio. Since 1990, MMFs have paid individual investors an extra $240 billion in yield over what they would have earned in comparable bank products. The strict risk-limiting regulation and prudent professional management of MMFs have produced a record of stability for 40 years. New regulations since the financial crisis have made these funds stronger and more resilient.
I urge the SEC not to issue regulations that could eliminate this vital tool for saving and investing.