SIFMA provides comments to the Securities and Exchange Commission (SEC) on the proposed new and amended rules and forms relating to money File Number S7-03-13, Release No. IC-30551. This letter has been prepared by the Asset Management Group of SIFMA and the Private Client Group of SIFMA, working together with SIFMA’s Municipal Securities, Operations and Technology, Accounting and Taxation divisions.

SIFMA supports the SEC’s goals of further reducing money market funds’ susceptibility to heavy redemptions, improving their ability to manage and mitigate potential contagion from such redemptions and increasing the transparency of their risks, while preserving, as much as possible, the benefits of money market funds.

While SIFMA supports the Commission’s goals, the group shares deep concerns that certain of the proposed reforms would either obstruct the operation of money market funds or alter their indispensable characteristics, harming shareholders who rely on them as a cash management tool and issuers who depend on money market funds as an important source of financing.