Subject: File No. S7-03-13
From: Joseph Ratto

July 16, 2013

Dear Sir: I would like to comment on the proposed change to money market funds and a floating or changed NAV. I think this is preposterous and frightening for small investors in the range of $500,000 or less, as I am one. I consider money markets a safe investment, and do not want to worry that the value will change from day to day or due to a market or government financial shock. Unless I am slightly deranged, I thought the stock brokerages and investment accounts were keeping this money invested in safe U.S. treasury accounts or in bank accounts, thus the term "Money Market" account. The account is in money or the equivalent of money. Maybe that is what should be changed. That these accounts should be in shortest term U.S. treasury bills and laddered so as essentially riskless or in cash (money). And then the change in value that may occur if the yield went up or a small portion and price went down, the institution would forfeit that loss accordingly. Investment institutions are given too much leeway to invest these funds, which should be safe and worth $1.00 always (constant NAV). There should not be some risk these funds. They are not an investment. And the risk should not carried by the investors, as most of the time, the investors is not knowledgeable about the investment vehicles, unless one requests a detailed listing of those investment. Why should a money market account carry an "investor beware" signature, or a need to carefully study how the money market money is invested.

I think there will be a run on money market accounts, if these floating changes are made, as more investors will open straight bank accounts. I know that I will. And there is quite a large percentage of money in money market accounts at this time.

Joe Ratto