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