The FSB’s Consultative Document Related to Policy Recommendations for Money Market Funds

SIFMA provides comments to the Financial Stability Board (FSB) on FSB’s Consultative Document An Integrated Overview of Policy Recommendations dated 18 November 2012 relating to policy recommendations for money market funds of the International Organization of Securities Commissions (IOSCO) dated October 2012. SIFMA suggests guiding principles which should inform any money market fund reform – tailor reforms as narrowly as possible given the possibility of dislocations that could result from reform; only pursue reforms that bear on the stated goal of reducing the perceived susceptibility of money market funds to destabilizing runs; and carefully consider the need for transparency and simplicity. To support transparency, SIFMA suggests requiring more frequent public disclosure of market based net asset value and portfolio holdings-related information.