Comments on Proposed Rule: Removal of Certain References to Credit Ratings and Amendment to the Issuer Diversification Requirement in the Money Market Fund Rule; References to Credit Ratings in Certain Investment Company Act Rules and Forms

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Date Received
Date Letter Type Commenter Name
Public Comment Barbara G. Novick, Vice Chairman and Richard K. Hoerner, CFA, Managing Director, Co-Head of Global Cash Management, BlackRock, Inc.
Public Comment David J. Lekich, Senior Vice President and Chief Counsel, Charles Schwab Investment Management, Inc.
Public Comment Dennis M. Kelleher, President & CEO, Better Markets, Inc.; Stephen W. Hall, Securities Specialist, Better Markets, Inc.; and Todd Phillips, Attorney (Bar Application Pending), Better Markets, Inc.
Public Comment Dorothy Donohue, Deputy General Counsel - Securities Regulation, Investment Company lnstitute
Public Comment Gregory Davis, Global Head of Fixed Income, Vanguard
Public Comment J. Charles Cardona, President, Dreyfus Corporation
Public Comment James Allen, CFA, Head, Capital Markets Policy, CFA Institute and Matt Orsagh, CFA, Director, Capital Markets Policy, CFA Institute
Public Comment Kathryn L. Quirk, Chair, Committee on Investment Management Regulation of the New York City Bar
Public Comment LuAnn S. Katz, Head of Global Liquidity, Invesco Ltd.
Public Comment Micah Hauptman, Financial Services Counsel, Consumer Federation of America
Public Comment Richard Johns, Structured Finance Industry Group
Public Comment Scott C. Goebel, Senior Vice President, General Counsel, Fidelity Investments
Public Comment Timothy W. Cameron, Managing Director, SIFMA Asset Management Group - Head and John Maurello, Managing Director, SIFMA Private Client Group
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an October 8, 2014, meeting with representatives of Fidelity
Public Comment Amy B.R. Lancellotta, Managing Director, Independent Directors Council
Public Comment David B. Smith, Jr., Executive Vice President and General Counsel, Mutual Fund Directors Forum
Public Comment Chris Barnard, Germany
Public Comment Carrie Devorah
Public Comment Michael Mark-Berger, Nursing Home Analyst, Chicago, Illinois
Public Comment Rep. Sean P. Duffy, Member of Congress
Public Comment Kurt N. Schacht, Managing Director, Standards and Financial Market Integrity, and Linda L. Rittenhouse, Director, Capital Markets Policy, CFA Institute
Public Comment Kenneth J. Berman, Chairman, Committee on Investment Management Regulation, The Association of the Bar of the City of New York, New York City, New York
Public Comment Scott Goebel, Senior Vice President and General Counsel, Fidelity Management & Research Company
Public Comment Gus Sauter, Managing Director and Chief Investment Officer, Vanguard, Valley Forge, Pennsylvania
Public Comment Americans for Financial Reform
Public Comment Barbara Roper, Director of Investor Protection, Consumer Federation of America
Public Comment David B. Smith, Jr., Executive Vice President and General Counsel, Mutual Fund Directors Forum
Public Comment David J. Lekich, Vice President and Acting Chief Counsel, Charles Schwab Investment Management, Inc., San Francisco, California
Public Comment David Messman, Secretary and Chief Legal Officer, Wells Fargo Funds Management, LLC, San Francisco, California
Public Comment David Oestreicher, Chief Legal Counsel; Joseph K. Lynagh Vice President and Portfolio Manager; Darrell N. Braman, Managing Counsel; Fran Pollack-Matz, Senior Legal Counsel; T. Rowe Price Associates, Inc., Baltimore, Maryland

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-07-11
Release Number
IC-31184
33-9193
IC-29592
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