Date: April 23, 2014

Issue: Money Market Funds


Filing Type: SEC

Description: While the CCMC appreciates the efforts of the Commission to provide transparency and seek comment on certain analyses of data and academic literature related to a discrete set of issues concerning the Proposal, we believe that an impact analysis should also be conducted on the Proposal’s impact on cash management practices of American business, including and the commercial paper markets and the availability of other efficient, low-cost short-term financing. We believe that such analysis will demonstrate the marginal benefit of a floating NAV does not justify the substantial costs imposed all stakeholders. As the SEC works toward a final rule on money market mutual funds, we urge the Commission to ensure appropriate analysis is completed to avoid any action that could cause serious and unwarranted harm to capital formation, competition and efficiency of American businesses and the economy.

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