Groups Opposing a Floating NAV Requirement for Money Market Funds

In its June 2009 proposal to amend Rule 2a-7 governing money market funds, the Securities and Exchange Commission requested public comments on whether these funds should be required to abandon the stable $1.00 net asset value (NAV). Specifically, the SEC requested comments on the possibility of eliminating the ability of money market funds to use the amortized cost method of valuation, forcing them to float their NAV. The following organizations and firms submitted comments in opposition to requiring a floating NAV. They represent a broad spectrum of businesses, governments, schools, retirement plans, consumer groups, and financial services firms.

• AARP
• American Bankers Association
• American Bar Association, Committee on Federal Regulation of Securities, Business Law Section
• American Benefits Council
• American Public Power Association
• Association for Financial Professionals
• Association of Public and Land-Grant Universities
• Bankers Trust Company
• BlackRock, Inc.
• Calvert Group, Ltd.
• Capital Management of the Carolinas, LLC
• Charles Schwab Investment Management
• City of Charlotte, NC
• City of Rocky Mount, NC
• City of Winston-Salem, NC
• City of Brookfield, WI
• Council of Infrastructure Financing Authorities
• Crane Data LLC
• Dreyfus Corporation
• FAF Advisors, Inc.
• Federated Investors, Inc.
• Fidelity Investments
• Fifth Third Asset Management, Inc.
• Fund Democracy
• GE Asset Management
• Goldman Sachs Asset Management, Inc.
• Government Finance Officers Association
• GW Capital Management, LLC
• HighMark Capital Management, Inc.
• Hillsborough County, NH
• Independent Directors Council
• Independent Trustees of the North
• Institutional Money Market Funds Association
• International City/County Management Association
• Invesco Aim Advisors, Inc.
• Investment Company Institute
• J.P. Morgan Chase Asset Management, Inc.
• Mutual Fund Directors Forum
• National Association of College and University Business Officers
• National Association of Counties
• National Association of County Collectors, Treasurers and Finance Officers
• National Association of State Auditors, Comptrollers and Treasurers
• National Association of State Treasurers
• National League of Cities
• Northern Funds and Northern Institutional Funds
• Northern Trust Investments
• Pennsylvania School District Liquid Asset Fund Board of Trustees
• Pioneer Bank & Trust
• Profit Sharing/401k Council of America
• RidgeWorth Investments
• RiverSource Investments, LLC
• Russell Investment Management Company
• Securities Industry & Financial Markets Association
• State of Rhode Island and Providence Plantations
• State Street Global Advisors
• Stradley Ronan Stevens & Young LLP
• SVB Asset Management
• Tamarack Funds Trust
• TD Asset Management
• Treasury Strategies
• UBS Global Asset Management
• U.S. Chamber of Commerce Center for Capital Markets Competitiveness
• U.S. Conference of Mayors
• USAA Investment Management Company
• Vanguard Group, Inc.
• Victory Capital Management
• West Coast Trust Company