Subject: File No. S7-11-09
From: Vera B Lichtenberger

September 3, 2009

Comment on SEC Proposed Money Market Rule

Monthly disclosure of portfolio holdings

The requirement for monthly reporting of portfolio holdings is an additional administrative burden on funds which are currently yielding very little today.

1. The proposal is for filing within two business days of the end of the month the portfolio holdings. This timing is a burden on small funds. Currently a fund has 60 days to report portfolio holdings. A 10 day period would allow for the filing staff to occasionally take a vacation without worrying about the SEC filing for the month.
2. The format of the filing may place an additional burden on the fund. The information needed is readily available, but once the SEC requires it to be in XBRL format (or other format not in the funds accounting system), the fund will need to hire a translating firm (or buy software and train staff) for the filing. Itll cost us.
3. It is mentioned that many firms already provide portfolio holdings on the fund website each month. For the investor who is interested in reviewing this information, the funds with timely disclosure can be selected. The marketplace will reward those firms who provide the additional disclosure. An investor is more likely to go to for fund information than
4. Once all the other safeguards of the proposed rule are adopted, the SEC will have less need to review the global holdings of all money market funds. In a stressed market, they can always ask the funds to give them additional information, as they did in September 2008.