Subject: File No. S7-03-13
From: Thomas Lupinacci

June 17, 2013

I personally use a MMF as a holding position for available money funds to be invested as I see fit. Under that scenario to have a floating rate MMF would generate a tax form for each and every transaction making an onerous amount of paperwork for thousands of investors and their respective brokerage firms.
Whereas a mandated "holdback" of available funds, though not desirable, would at least reduce the amount of paperwork and record keeping necessitated as mentioned in the first paragraph.
Thank you.