Letter to SEC on Potential Money Market Fund Reform Measures

Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549–1090

Dear Ms. Countryman:

The American Bankers Association (ABA) appreciates the opportunity to comment on potential reforms for certain money market funds (MMFs) raised in the December 2020 report of the President’s Working Group on Financial Markets. The Securities and Exchange Commission (SEC) is requesting comments on these potential reforms to improve stability of MMFs specifically and the short-term funding markets, generally.

Banks and their affiliates interact with prime MMFs in numerous ways, including as investors on behalf of bank customers, as sponsors of MMFs, and issuers of certificates of deposit and commercial paper in which prime MMFs invest. In addition, as participants in the short-term funding markets, banks have a great interest in maintaining and improving general market stability. We understand that the SEC is working in conjunction with other federal financial regulators through the President’s Working Group (PWG) and Financial Stability Oversight Council (FSOC) on MMF reforms, as well as with international standard-setting bodies, such as the Financial Stability Board (FSB) and the International Organization of Securities Commissions. We make these comments for the broader audience, while acknowledging the SEC’s focus on their regulatory authority over MMFs.

Download the comment letter to read the full text.