Futures Commission Merchant Regulation - Comment Letter - Dreyfus - December 3, 2010

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Dodd-Frank Timeline, Investment of Customer Funds
Final Rule Issue Effective Date Compliance Deadline
December 19, 2011 February 17, 2012 June 18, 2012

Investment of Customer Funds and Credit Ratings
December 3, 2010

Summary of points from the comment letter:

  • Dreyfus suggests a concentration limit of 50 percent for government and agency money market funds, and 25 percent for prime and municipal money market funds.
  • Issuer-based concentration limits are unnecessary and "do not enhance the safety" of client assets.
  • Dreyfus would not support limiting permitted investments to U.S. Treasury funds, as other types of money market funds are "subject to sufficient risk-limiting constraints."



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