Comment Letter on Money Market Fund Reform


Comment Letter on Money Market Fund Reform

By Graham Hunt

10/07/13, 12:43 PM CT | Author: Tiffany Adams

On Monday, September 30, The Federal Regulation of Securities Committee submitted a comment letter to the U.S. Securities and Exchange Commission. The letter is the Committee’s response to the SEC’s request for comments on the proposed amendments to rule 2a-7 under the Investment Company Act of 1940.

The letter addresses the following:

  • Floating Net Asset Value
  • Standby Liquidity Fees and Gates Proposal
  • Issues for Variable Annuity Contracts
  • Proposed Amendments Relating to Money Market Fund Advertising
  • Modification of Investment Objectives and Policies
  • A Floating Net Asset Value – Transparency and Market-Based Pricing

The comment letter drafting committee included  Jay G. Baris (Vice-chair of Programs, Federal Regulation of Securities Committee; Chair, Investment Company Use of Derivatives and Leverage Task Force), Stuart H. Coleman, Catherine T. Dixon (Chair, Federal Regulation of Securities Committee), Alison M. Fuller, Roger P. Joseph, Martin E. Lybecker (Immediate Past Chair, ABA Business Law Section), Mark D. Perlow, Eric D. Roiter, and Robert G. Zach.

Join the Federal Regulation of Securities Committee to begin receiving notifications about comment letters, and other Committee resources, including newsletters, webinars, CLE, program materials, and annual reviews. Committee membership is free for all Business Law Section members.

If you’re interested in the content covered by the Federal Regulation of Securities Committee, you may want to attend the Business Law Section Fall Meeting. The Fall Meeting schedule includes the following programs and meetings focused on securities regulation:

  • A Capital Markets Conversation with the SEC (CLE)
  • Invest in this Offering! The Brave New World of General Solicitation in Rule 506 Offerings (CLE)
  • Investment Management: Current Enforcement and Compliance Issues (CLE)
  • PCAOB and SEC Accounting/Auditing Issues (CLE)
  • Civil Litigation and SEC Enforcement Matters Subcommittee Meeting
  • Dialogue with the Director
  • Disclosure and Continuous Reporting Subcommittee Meeting
  • FINRA Corporate Financing Rules Subcommittee Meeting
  • Hedge Funds Subcommittee Meeting
  • International Securities Matters Subcommittee Meeting
  • Investment Companies and Investment Advisers Subcommittee Meeting
  • Proxy Statements and Business Combinations Subcommittee Meeting
  • Securities Registration Subcommittee Meeting
  • Small Business Issuers Subcommittee Meeting
  • Trading and Markets Subcommittee Meeting
  • Employee Benefits, Executive Compensation, and Section 16 Subcommittee Meeting
  • Securities Activities of Insurance Companies Subcommittee Meeting
  • Securities Law Opinions Subcommittee Meeting

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