On April 25, the Forum filed a comment letter with the SEC regarding a rule proposal published in March that, if adopted, would remove all references to credit ratings from the rules governing money market funds. The SEC proposed the rule changes in response to the Dodd-Frank Act, which requires all federal agencies to remove any references to credit ratings from their rules.
The letter reiterates the Forum's concerns with removing references to credit ratings in the money market fund context because of the potential that such changes would create additional risks in money market funds. The letter also urges that if the rules are ultimately adopted, the SEC should make clear that funds voluntarily may continue to use credit ratings as one tool to assess credit quality.
The Forum's comment letter is available at: http://www.mfdf.org/images/uploads/newsroom/MFDF_2a-7_Comment_Letter.pdf