Yet another mutual fund industry heavyweight, Dechert LLP, has weighed in on the debate surrounding possible changes to money market mutual fund regulations. The law firm's most recent "Dechert OnPoint" newsletter features an article entitled, "Report of the ICI Money Market Working Group and Other Money Market Fund Reform Proposal. The update discusses the ICI MMWG's recent proposals in detail, and suggests that funds should begin implementing these recommendations.

Dechert's Financial Services Group writes, "In response to the financial crisis, various governmental authorities and non-governmental organizations have made proposals to reform the regulation and oversight of money market mutual funds. On March 17, 2009, the Investment Company Institute's Money Market Working Group released its report, which includes a series of recommendations designed to "respond directly to weaknesses in current money market fund regulation, identify additional reforms that will improve the safety and oversight of money market funds, and ... position responsible government agencies to oversee the orderly functioning of the money market more effectively.""

They add, "The report notes that many of its recommendations can, and should, be implemented voluntarily by money market funds in advance of formal SEC rulemaking, and that "[i]t should be the goal of all money market funds to substantially implement [the Report's] recommendations by September 18, 2009.""

Dechert explains, "While the ICI Report represents the most comprehensive of the money market fund reform proposals released to date, various other parties have issued their own proposals for money market fund reform. Earlier in the year, a steering committee of the Group of Thirty released a series of financial reform recommendations that included proposals to completely change the way money market funds are structured and regulated. More recently, Treasury Secretary Timothy Geithner and Federal Reserve Chairman Ben Bernanke separately outlined their own proposals for reforming the regulation of money market funds."

The article summarizes, "This update discusses the recommendations in the [ICI] Report, and compares them with the reform proposals offered or outlined by the G30, Chairman Bernanke, and Secretary Geithner."

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