First American Funds, which manages almost $​50 billion in money funds (​all AAA rated), comments on the SEC'​s proposed "​Broker-​Dealer Responsibility Rules". The adviser urges the Commission to allow AAA rated money funds as "​qualifed securities" under Rule 15c3-​3. Currently, the proposed rules only allow Government funds to be used as brokerage collateral, but many are urging the SEC to include "​prime" funds.

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