Submitted by: Submitted by optical05
Views: 370
Words: 965
Pages: 4
Category: Business and Industry
Date Submitted: 09/27/2011 09:15 AM
Paul A. Volcker
11 February 2011 Elizabeth M. Murphy, Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-1090 Re: President’s Working Group Report on Money Market Fund Reform; Release No. IC‐29497; File No. 4‐619 Dear Ms. Murphy: The widespread run on money market funds during the financial crisis illustrates the risk that is present in large financial institutions that operate with little or no capital and supervision, yet provide the very maturity transformation and liquidity “service” expected from our regulated, well capitalized banking system. When the crisis hit, certain sponsors of Money Market Mutual Funds ‐ banks, investment banks, insurance companies and asset management firms ‐ injected significant amounts of capital into their Funds to preserve the par value of customers’ investments. The purpose was both to protect the reputations of their respective firms and limit the contagious panic of investors withdrawing money at a rapid rate. Several of these sponsoring institutions, facing a shortage of capital and liquidity due to these and other losses during the crisis, received support from different government facilities including the TARP. The Prime Reserve Fund, which operated independently, was the main direct recipient of government assistance via unprecedented use of the Exchange Stabilization Fund of the U. S. Treasury. Massive Federal Reserve purchases of commercial paper were driven by the need to protect MMMFs. Among these were well managed Funds that experienced a shortage of liquidity, and of course Funds that invested in poor quality securities. 1 The risk in these Funds has been compounded by the addition of cash management services, including withdrawal of fund principal on demand at par, thereby closely mimicking the services provided by regulated commercial banks. While the recent amendments to Rule ...