Date: January 23, 2013
Issue: Money Market Mutual Funds
To: Financial Stability Oversight Council
Filing Type: Regulatory
Description: CCMC submitted a comment letter to the Financial Stability Oversight Council (FSOC) on proposed recommendations to the SEC under Section 120 of Dodd-Frank regarding money market mutual funds (MMMFs). While CCMC continues to support regulations that strengthen MMMFs, the three alternatives proposed by the FSOC will fundamentally alter the structure and nature of MMMFs by limiting their utility as a critical source of investing and short-term financing for the business community. The letter focuses on our concerns with the three proposals and the inadequate process and the dubious legal authority the Council asserts for invoking Section 120 of Dodd-Frank.