Subject: File No. 4-619
From: Brian Smith

August 13, 2012

Chairman Schapiro
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Dear Chairman Schapiro:

Dear Ms Schapiro and Mr Sperling:

I am writing to express my concern regarding proposed changes to the Money Market rules.

My clients are predominantly retired, and their biggest worry is the loss of value of their money. A stable value investment such as a Money Market is now the foundation for all my cliients' financial security, and I suspect the vast majority of retirees use a Money Market vehicle for the same reasons.

Please do not alter the regulations to allow a floating NAV on Money Market Funds. There must be a better way to address your concerns than to increase the uncertanty for the average American. They already put up with significant uncertanty in the investment markets, and allowing or requiring a floating NAV on Money Market funds adds one more uncertanty.


Brian Smith