Subject: File No. S7-03-13
From: John Friedrich

September 13, 2013

Elizabeth M. Murphy
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

 

Dear Elizabeth Murphy:

I've been doing the math programming for Money Market Funds for two decades.  The proposed changes to let the NAV float would destroy the money market industry.  Right now, the interest rates are extremely low, and money market funds pay very little money.  The costs of programming and enforcing all these new regulations would force the money market funds to close to avoid taking huge losses.  This would result in widescale unemployment for the employees who have worked in the money market industry, as well as the loss of a safe place for companies to store their excess cash for short-term investment.

If regulations must be passed, the proposed redemption gates would be least harmful.  They would not change the fundamental nature of money market funds, and companies would only have to adjust their policies in time of a dire financial crisis.

Cordially,

 

John Friedrich