From: Bruce Bent,
Sent: June 13, 2007
To: rule-comments@sec.gov
Subject: File No. S7-08-07

As the creator of The World's First Money Fund "The Reserve Fund" I applaud their inclusion as a "qualified security".

In response to your limitations:

1. 2a-7 funds only. Agree.

2. Full faith and credit of the U.S. Treasury only. Disagree.
Thirty years and three trillion dollars later, triple "A" rated money funds, Primary, Government and Treasury are all totally proven quanities particularly since you are further limiting investments to funds that have assets equal to 10 times the customer assets deposited.

Please clarify; if a fund has assets of $10 million will they be limited to $1 million of 15c3-3 balances in the aggregate or, $1 million from each of a theoretically infinite number of firms (obviously growing as the asset of the fund increases).

3. One day redemption is acceptable but should be same day for redemption prior to 2:00 p.m. It is rare that any Reserve Fund has less than a 20% overnight position so sales would not be necessary even for same day redemption.

. Fund assets of 10 times the assets invested is excessive. 5 times should not be a problem in a triple "A" fund.

Bruce Bent, Chairman
The Reserve
1250 Broadway, 32nd Floor
New York, NY 10001