Subject: File No. S7-08-07
From: Peter G Crane
Affiliation: President, Crane Data LLC; Publisher Money Fund Intelligence

April 22, 2007

Overall, the money market mutual fund advisor and investor community applauds the proposed rule. Given the safety record of money market mutual funds, the Commission should consider removing the "Government" and "large" conditions on money funds used for brokerage customer reserve deposit requirements. "Prime" money funds have an even better safety record than "government" money funds over the years. (The only money fund to "break the buck" ever was a Government fund, and government funds have seen more problems than prime over the years.) Prime money funds overall are much larger than government funds, so the size restriction wouldn't be necessary either. On the sweep accounts, it is extremely difficult to find "bankerage" rates, so I'd suggest requiring brokerages to publish their current rates. (I think they're supposed to be doing this, but good luck finding them)
I hope these are helpful.
Pete Crane
Publisher, Money Fund Intelligence