Subject: File No. 4-619
From: Tom Welch

December 26, 2010

I oppose any policy option for money market funds that would require a floating net asset value (NAV) for both institutional and retail investors.

Removing the option of a stable $1.00 NAV fund for institutional investors would effectively kill the market for these funds, as they provide a stable investment vehicle for institutions that is in fact mandated by many institutions' treasury policies.

Driving investors out of these funds would in turn severely restrict the market for short-term commercial paper, as such funds purchase approximately one third of such instruments.

Any futher policy action regarding money market funds should maintain the availability of stable NAV funds for both institutional and retail investors.