Futures Commission Merchant Regulation - Comment Letter - UBS Global Asset Management - 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

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.


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