TAILIEUCHUNG - Financial Stability Oversight Council’s Proposed Recommendations Regarding Money Market Mutual Fund Reform (the “Proposal”), FSOC–2012–0003, 77 FR 69455, November 19, 2012.

Company Act of 1940. 14 If the current rules were in place in 2007 and 2008, prime MMMFs could still have held the distressed asset-backed commercial paper and Lehman debt securities that triggered support for many funds and the break the buck event for the Reserve Fund. Indeed, Lehman debt maintained the highest short term ratings up through the time it filed for bankruptcy. 15 And recent sponsor behavior indicates that support is still a likely event in the face of such credit events or uncertainty. Although no MMMF holdings have defaulted since 2008, two Northern Trust funds 16 disclosed the purchase. | FEDERAL RESERVE BANK OF BOSTON 600 ATLANTIC AVENUE BOSTON MA 02210 ERIC s. ROSENGREN PRESIDENT AND CHIEF EXECUTIVE OFFICER February 12 2013 PHONE FAX Financial Stability Oversight Council Attention Amias Gerety 1500 Pennsylvania Avenue NW Washington DC 20220 Re Financial Stability Oversight Council s Proposed Recommendations Regarding Money Market Mutual Fund Reform the Proposal FSOC-2012-0003 77 FR 69455 November 19 2012. To Financial Stability Oversight Council I am writing on behalf of the Presidents of the 12 Federal Reserve Banks all of whom are signatories to this We appreciate the opportunity to respond to the request for comment on the Proposed Recommendations Regarding Money Market Mutual Fund MMF Reform the Proposal issued by the Financial Stability Oversight Council the Council on November 19 We agree with the Council s proposed determination that the conduct nature size scale concentration and interconnectedness of MMFs activities and practices could create or increase the risk of significant liquidity and credit problems spreading among bank holding companies nonbank financial companies and the financial markets of the United For this reason we support the Council s efforts to address the structural vulnerabilities of MMFs by releasing the Proposal. Our comments in this letter will focus primarily on prime MMFs4 where the greatest credit risk5 can be taken and where financial stability risks consequently appear to be the greatest. Once reforms are instituted to address the structural vulnerabilities of prime MMFs we would encourage consideration of what reforms if any are worth pursuing for other categories of MMFs. As support for the Council s proposed determination and to set the context for identifying the essential elements of reform we briefly discuss some of the risks associated with MMFs activities and practices in Section I. Section II focuses on issues that should be addressed

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