August 7, 2013
Elizabeth M. Murphy
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Dear Elizabeth Murphy:
My clients rely on MMFs. Changing the structure so that the stable $1.00 net asset value is lost would negatively affect their ability to manage investments and cash flows.
My clients understand that MMFs are investments that are not guaranteed by the government or anyone else. Adopting a floating NAV would create accounting, tax and administrative nightmares by, requiring the tracking of minute increases or decreases in share price each time client shares are bought or sold. It is also critical that the SEC maintain the present system of same-day settlement.
I ask you to look closely at the serious and widespread fallout that would occur with a floating NAV, as well as how gating might address the needs
of all MMF stakeholders. We hope that the SEC will take our views into
In light of the 2010 regulatory reforms instituted by the SEC, money market funds are working well. We urge the SEC not to regulate MMFs out of existence since there are no other financial products available that provide the same flexibility, yield and value as MMFs.