Subject: File No. S7-11-09
From: David C. Rhodes
Affiliation: Principal Engineer

July 28, 2009

MMF's have operated for over two dozen years and have provided an investment with stable and reliable returns, while supplying commerce with a source of funding that fuels growth. Presumably, the rule changes are being considered because of one instance where an MMF "broke the buck". This occurred only once only under the most stressing economic conditions. The fact that they have fared so well, argues that the rules be left untouched. Don't change an MMF system that has worked so well because of a single instance of difficulty. Surely fund managers will take note and adjust to protect their own funds.

Don't change a system that is working well.