Subject: File No. S7-11-09
From: James L. Nesfield, Mr.
Affiliation: Fisherman

July 4, 2009

The notion of imposing risk limitations on the portfolio holdings based on ratings assigned by an NSRO is absurd. The genesis of the issue is the lack of transparency at a granular level i.e. the actual real time accounting facts pertaining to a corporate issuers condition. The alternative would be to have Money Market Funds placing on a brokered basis deposits in FDIC insured banks. The primary issue is one of no accountability versus the fantasy that exist today. The FDIC route of insuring deposits is exploited primarily by other spread players namely the Credit Unions and the Bureau of Indian Affairs who are also Federally Insured but place their funds within another Federally insured entity compounding and accelerating the Hot Money scenario. Ultimately the decision to buy a short term obligation must be based on credit and this means the portfolio managers must know the true accounting of the corporate entity, the idiocy of the NSRO regime removed, and investors must have a peek through of the portfolio holdings. If one had the intent of removing risk they are fabricating another piece of pavement to hell, but if one wished to treat market participants as sentient beings rather than cannon fodder, then one would open the accounting records to some level, remove the non-competitive NSRO standard and stop pretending that this mad dash to implement the dialectical standards of Karl Marx are anything other than something Groucho Marx would attempt. Stop pretending to regulate and try and understand the dynamics of the systemic flaws the SEC has implemented via the NSRO failed regime. The Securities Markets are now as much a part of the Federally mandated regime and as such have an answer to resorting credibility, that answer is remove the regulations, demand publication of factual conditions to determine risk, and let the buyer beware. Laissez faire is something too subtle for Socialist grasp but the only required stance, unless you want the Federal Socialist Republic of the United States to insure every investment, thus rendering the old statement made in the USSR "We pretend to work and you pretend to pay us" replaced with "We pretend to invest and you pretend to insure". Get out of the Money Market game it was not something intended for those without quarterly reporting time frames it is too robust for the likes of a Federal Bureaucracy, let those seeking short term liquidity and no risk generate Hot Money via brokered deposits to FDIC insured accounts they seem to know how to handle the risk. Happy Independence Day lets end our self imposed tyranny and attempt to treat each other as free, informed, and capable people.