August 29, 2013
My firm is a registered investment advisor. I am concerned that the proposal would potentially eliminate an important short-term investment option for our clients and potentially make the markets less liquid.
We use money market funds as a liquidity option for virtually all our clients. The floating NAV would destroy the utility of the funds. Most of our users require safe liquid cash equivalent investments that avoid cap gains or losses. When used for the settlement of securities transactions, the accounting could be a nightmare. I also dont understand the proposed distinction between retail institutional.
I understand that the SEC is responding to concerns about the potential for a run on money market funds during a financial crisis like the one we had in 2008. But there are less destructive ways than a floating NAV to achieve the SECs objective. Possibly in a crisis, for example, allowing a fund to have the ability to temporarily suspend redemptions if doing so is necessary to prevent the fund from breaking the buck or losing its liquidity. Such action would serve as a type of circuit breaker in an extreme crisis, giving the markets time to calm. Fund shareholders would be less likely to panic if they know they will have access to their assets when the fund reopens after a short suspension of redemptions. And the impact would only be felt during a crisis, not all the time as with the floating NAV proposal.
Please do not adopt the floating NAV proposal, which would impose needless costs with loss of efficiency, convenience, and return for our customers.
Thank you for your consideration.