Date: February 13, 2013

Issue: Money Market Mutual Funds

To: Securities and Exchange Commission

Filing Type: Regulatory

Description: CCMC sent a letter to SEC Chairman Walter highlighting issues that companies, states, and municipalities would face with the imposition of a floating net asset value (NAV), and raises questions that the SEC should consider as it works toward a proposal on the further regulation of Money Market Mutual Funds (MMMFs).  We understand that the SEC  is considering concepts included in the Financial Stability Oversight Council’s (FSOC) proposed recommendations, including adoption of floating net asset values (“NAVs”) along with the elimination of amortized cost accounting that facilitates a stable NAV.  The letter emphasizes that the SEC by itself cannot make a floating NAV work without rendering the utility of MMMFs useless. We believe it is incumbent on the SEC to work jointly with other bodies to ensure all issues are addressed before any rule change is adopted.

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