Credit Ratings Regulation - Comment Letter - SIFMA - April 18, 2011

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Timeline, References to Credit Ratings in Money Market Fund Rules, SEC
Proposal Date Re-proposed Rule Comment Deadline
March 9, 2011 July 24, 2014 60 Days After Federal Register

References to Credit Ratings in Certain Investment Company Act Rules and Forms
April 18, 2011

The Asset Management Group (AMG) of SIFMA sets forth the following comments in the letter:

  • "Section 939A of the Dodd-Frank Act is not intended to require elimination of references to ratings in Rule 2a-7;
  • References to credit ratings in Rule 2a-7 benefit money market fund shareholders and should be retained;
  • Section 939A of the Dodd-Frank Act does not apply to Form N-MFP, which is a disclosure form, rather than a quality assessment requirement; and
  • If the Commission concludes that Section 939A requires removal of ratings from Rule 2a-7, we support efforts to urge Congress to amend Section 939A so that it will direct regulators to require that ratings-based determinations be accompanied by additional credit risk analysis, rather than requiring removal of references to ratings."

SIFMA believes that the removal of references to credit ratings in Rule 2a-7 and in Form N-MFP would impose additional risks on the investment decisions of money market fund shareholders and operators and that the costs of such an amendment would outweigh the benefits.

References[edit]

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