July 28, 2014
My commentary on proposed ruling S7-07-11 is as follows. With regards to the Credit Rating References in section 939A of the Dodd-Frank act that the securities and exchange commission shall continue to use NRSRA's (Nationally recognized statistical rating agencies) to be the grader so to speak on the credit worthiness of any money market instrument or security.
Any and all amendments that have been created to rule 2a-7 and Form N-MFP from years past should be a reflection of the greater general population not only in Chicago but throughout our country for their thirst to receive more transparency and accuracy from qualified rating agencies that the public is able to see. As an industry analyst in the nursing home industry here in Chicago I Michael Mark Berger would like to see qualified rating agencies listed here to let the general public know that more transparency is being divulged.
Rule 2a-7 concerning money market funds is highly applauded here in the Midwest and northeast as calculating the current net asset value on a per share basis when valuing portfolios based on current market pricing will help to continue safety nets in our financial system so that we can avoid the collapse and calamity that was caused after Lehman Brothers collapsed and we "broke the buck" on the money market funds which ensued chaos and a severe run on our financial system which was stemmed and saved thanks to the work of our fiscal policy and governmental employees.
For money market funds to maintain stable share pricing they need to be required to outlay a low level of risk and not look to seek above alpha returns. Reducing principal volatility is also crucial as I would recommend that a system is in place that measures the deviation of the money market funds and the current volatility index (VIX) which can be followed on the Chicago Board of Exchange (CBOE).
When asking to remove references to credit agencies I Michael Mark Berger of Chicago, Illinois feel it is a negative move and may lead to the law of unintended consequences because the first element of "Determination" of an eligible security on the first tier, with credit quality, stress testing, and other credit events in place of standards of creditworthiness that we believe are appropriate.
It is agreed upon in my opinion that the determination of first tier and second tier securities is too difficult and should not be deemed a bad change as the commentors have agreed that it is in the best interest to eliminate and delete the references to ratings in the sec's rules in exchange for consistent standards of creditworthiness to a feasible extent.
In answering the question as to "consolidating the credit quality standard and eliminating the
distinction between first and second tier securities." You have asked if we the commenters believe "that the re-proposed standard is an appropriate standard of creditworthiness for rule 2a-7?"
While looking at other substitutions and discussing with other analysts both in the nursing home industry and in all walks of life here in Chicago I Michael Mark-Berger can say that it is with exceptionally strong capacity as an appropriate standard and substitute for credit ratings in rule 2a-7.
In closing on page 90 of the proposed ruling it does talk about the incurred costs and fees. It is agreed that the overall cost would be minimal and with greater transparency and less systemic risk all parties benefit more than they would lose over the long run.