On March 29, 2012, the Forum filed with the SEC a comment letter concerning significant money market fund reform options that the SEC is reportedly considering.
The letter makes two points, both premised on what appears to be a widely held view that if redemption restrictions or other major reforms are adopted, assets will leave money market funds. First, the draft letter emphasizes the unique role of directors in overseeing money market funds. The Forum highlights the benefits to shareholders of this governance structure, which may not be present in unregulated or off-shore cash management products. Second, the Forum's comment letter encourages the Commission to fully analyze potential systemic risk to the US financial markets of the assets currently within money market funds being moved to less regulated and/or less transparent cash management vehicles.