Subject: File No. S7-11-09
From: Kevin Krafft, MD

September 21, 2009

Dear Committee Members:

It is my opinion that the value of money market funds should not be allowed to float. This would change the inherent nature of the funds and eliminate a key component of any retirement portfolio, if only psychologically. As we have seen in past crises, the belief something is not stable is as strong as the reality and can initiate the the very reality feared. Floating injects another element of risk the average investor does not understand. Other safeguards can be placed by the committee to prevent the unintended consequences of a stable NAV. A continued voluntary insurance pool may be one idea.