Date: September 12, 2013

Issue: Money Market Fund Reform

To: SEC

Filing TypeRegulatory

Description:  In light of these concerns, we urge the SEC to reject the transition to a floating NAV especially for municipal MMMFs under its June 5, 2013 proposal. We firmly believe that this change will be harmful to cash management and short-term financing opportunities for municipalities like ours that rely on MMMFs for liquidity management. Furthermore, we believe that the shift to a floating NAV will ultimately pose significant risks the long-term health of the nation’s economy.

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