August 9, 2013
I am opposed to the floating NAV proposal. Banks enjoy use of deposit moneys to invest and have access to the Fed's wholesale window. If this proposal is made effective there will be no safe alternative for individuals other than bank investment vehicles. Instead of eliminating competition and creating monopolies for banks, rules propagated should create competition and level the playing field. Since banks are conveniently exempt from security laws this may be of little concern to the SEC, but it is a practical consideration to investors who prefer money market mutual funds to passbook savings accounts and CDs. Certainly I know that Money Markets are not guaranteed but keeping by requiring AAA composition for 95% of their holdings makes them nearly so or the next best thing. Please do not make this amendment without consideration of competitive alternatives to bank offerings. Doing so harms the public who you should seek to protect. Disclosure that they are not guaranteed accompanied by stringent holdings rules and enforcement actions for violations is wholly adequate and keeps the marketplace competitive.