ABA noted than many of ABA’s member institutions interact with MMFs in numerous ways, and are therefore keenly interested in FSOC’s proposed recommendations to the SEC. Therefore, ABA offered the following general comments on the proposed recommendations:
- First, there is very strong support for retaining a stable net asset value (NAV) MMF, as this product is preferred by trust departments and corporate trustees as a timely and economical way to invest short-term customer cash.
- Second, any regulatory action must avoid creating the perception that investments in MMFs are equivalent to insured bank deposit accounts in terms of federal supervision or backing.
- Third, the Council should carefully consider the sufficiency of the SEC’s 2010 reforms and give them adequate weight, as many bankers are convinced that further reforms are not needed.