June 6, 2013
Your proposed changes in regulations governing money market rules are both insufficent and excessive.
Imposing a "floating" value framework for money market funds simply acknowledges reality. But that reality applies to all funds, not just funds used by institutions. Individual investors would be better off if they understood clearly that guaranteeing money market shares at a dollar per share is, in fact, not possible. That has always been the case, and investors were always at risk.
Second, imposing a penalty on withdrawals during difficult to define times of crisis, only encourages pre-emptive runs on money market funds. This will encourage that which you hope to avoid.
Third, since it is impossible for any money market fund to guarantee the buck-per-share value, it would be useful for investors to have an alternative "safe harbor". Have you or any other regulator considered where investors could put their money for safety in times of financial stress?
Thank you for your time,