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
