Subject: File No. S7-22-21
From: Lisa Lynn

December 16, 2021

I oppose this rulemaking.

A single money market fund broker the buck in 2008 and in response we now have had 3 money market fund reform rules adopted/proposed since then. By the way, the Reserve Primary Fund ended up paying out investor $0.991 on the dollar, so it wasnt even a huge loss (though it did take awhile to pay out).

Doesnt this continually reform seem like overkill with no added facts? What has changed since the 2010 and 2014 reforms?

There was market stress in March of 2020 due largely to COVID. However, all money market funds weathered that storm and can built that experience into their stress testing.

Money market funds are an important asset class as well as an invaluable default investment (when servicing as a core account). The SEC should not create rules that further hinder, increase costs and reduce yields of these funds.