Business Law Society

Money market funds (MMFs) have been the most stable cash vehicle in history. Since MMFs arrived on the scene three decades ago, thousands of banks have failed, while MMFs have lost principal twice. In each case, losses ultimately suffered by investors were minuscule. And this record was achieved without FDIC insurance. Notwithstanding MMFs’ sterling record, the CFT has proposed to limit the use of MMFs: as collateral in swap transactions and for holding customers’ cash.

Federated letter to FSOC

Federated Letter to CFTC

Fund Democracy money market fund letter

Links related to proposed amendments to CFTC Rule 1.25:

Investment of Customer Funds and Funds Held in an Account for Foreign Futures and Foreign Options Transactions

Investment of Customer Funds and Funds Held in an Account for Foreign Futures and Foreign Options Transactions

CFTC Fact Sheet: Proposed Rule on Regulations 1.25 and 30.7 Regarding Investment of Customer Funds and Credit Ratings

CFTC Q&A: Regulation 1.25

Proposed Swaps collateral rules incorporating Rule 1.25

Protection of Cleared Swaps Customers Before and After Commodity Broker Bankruptcies, 75 FR 75162 (proposed rule)

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17 CFR Part 190

Comments Open Date: 12/2/2010

Comments Closing Date: 1/18/2011

Proposed Rule 75 FR 75432 //

17 CFR Parts 23 and 190 Protection of Collateral of Counterparties to Uncleared Swaps; Treatment of Securities in a Portfolio Margining Account in a Commodity Broker Bankruptcy

Comments Open Date: 12/3/2010

Comments Closing Date: 2/1/2011