Date: October 21, 2013

Issue:  Money Market Mutual Funds

To: Internal Revenue Service

Filing Type: Regulatory

Description:  The IRS’ proposed guidance only partially addresses the concerns of businesses that rely on MMFs for cash management. If the proposed guidance were to be implemented in its current form businesses will face higher costs, compliance burdens, and issuance of disclosures that may not be useful to the IRS or investors.

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