Futures Commission Merchant Regulation - Comment Letter - UBS Global Asset Management - December 3, 2010
|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
From the comment letter:
"Money market funds provide investors a greater degree of diversification and liquidity than many investment alternatives for which the CFTC has proposed higher issuer concentration and total investment limits. UBS Global AM submits that a more reasonable percentage limit on money market fund investment (if, indeed, any at all is required) might be 50%, with a 10% limitation on investment in any one fund."
The letter outlines its arguments that money market funds minimize credit, liquidity, and market risks.