September 1, 2013
Chair White and Commissioners:
I do not agree with this proposal.
Many who use money market funds as core accounts for checking will not understand the implications of this rule.
In addition, I do not like the following money market fund practices and think the SEC should rein in on them:
1. Advisors and sponsors rimbursing money market funds for fees charged to maintain a $1.00 NAV and then reserving the right to recoup the wiaver. This is making future investors subsidize current investors. In addition, a moneyu market fund summary prospectus does not disclose that this arrangement (recoupment) is in place.
2. Many moeny market funds reserve the riught to do a reverse stock split to maintain a $1.00 NAV; or hold back dividends to maintain a $1.00 NAV. This is smoke and mirrors designed to hide the fund's performance.