Subject: File No. S7-03-13
From: Helen Pantazakos
Affiliation: Operations Compliance Director

September 3, 2013

Proactive Advisors has used money market funds for client accounts for many years. The proposal under consideration to eliminate the $1.00 per share peg is harmful to investors, would hurt market liquidity, and remove safe havens for the public. Banks have morphed into the investment business over the years and still gamble with depositor's money still today by leveraging overnight repo securities. Yet they enjoy FDIC insurance and the implicit bailout of the US taxpayer up to the limits afforded by FDIC insurance and account registrations per client account. Treasury is protecting the banks, will the SEC not protect the Public?

The SEC's proposal to remove the $1.00 peg essentially advantages banks versus brokerage firms and adversely affects investment advisors. It makes banks the sole purveyor of liquid, safe-haven deposit vehicles available to the public seeking refuge from the markets. Neither alternative proposed by the SEC eliminates this bias towards the banks, though the second proposed amendment is certainly better. Certainly everyone understand the SEC seeks to prevent a run on money market funds in the event of another financial crisis, but the prudent way to accomplish this goal is to reel-in the banks who still use off-exchange derivative contracts and leverage repos. Instead of these proposals the SEC should work with Congress to change security laws to bring banks under the SEC and separate regulation from the purse. The market needs more liquidity not less. Please reconsider your proposal as it harms the public's investment alternative's and only gives banks more money to gamble while not resolving the underlying problem of market stability.