September 4, 2008
I urge the commission not to adopt the proposed rule change to Rule 2a-7. I believe that requiring money market funds to restrict investments to those receiving high ratings from the recognized rating agencies helps encourage investor confidence, and helps ensure the uniform stability and safety of money market funds in general. The rating agencies are widely, indeed almost universally, relied upon in determining the credit-worthiness of debt issuers and their debt instruments. Rule 2a-7 as presently written gives investors confidence that all money market funds are working to the same standards and present comparable investment risks. I strongly recommend the commission keep Rule 2a-7 as it now is.