The U.S. Chamber of Commerce’s Center for Capital Markets Competitiveness (“CCMC”) is pleased to provide comments on the proposal issued by the Securities and Exchange Commission (“SEC” or “Commission”) on “Money Market Fund Reforms” (“Proposal”). Rule 2a-7, the principal rule governing Money Market Funds (“MMFs”) under the Investment Company Act of 1940, was amended by the SEC in both 2010 and 2014, with the objectives of making MMFs “more resilient to certain short-term market risks” and addressing “risks of investor runs on money market funds, while preserving the benefits of the funds.” In its most recent effort to reform the rules surrounding MMFs, as a reaction to the market volatility of March 2020, the SEC states that the objective of its current proposed reforms is to improve MMF resilience and transparency.
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