Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-1090

Re: File No. S7-07-11

Dear Secretary Murphy: I am writing on behalf of the Consumer Federation of America (CFA)1 to express our continued opposition to the Commission’s proposal to eliminate the requirement that money market mutual funds limit their holdings to securities with the highest credit ratings.2 While we sympathize with the challenge the Commission faces in fulfilling its congressional mandate to remove all regulatory references to ratings, we do not believe the current proposal satisfies that mandate, which specifically directs regulators to adopt alternative standards of credit-worthiness to substitute for reliance on ratings. Because the Commission proposal eliminates references to ratings without putting anything in their place, and because it continues to allow fund directors and managers to rely heavily on ratings in conducting their own evaluation of credit-worthiness, we do not believe it would result in the significantly reduced reliance on ratings that Congress intended. Nor would it make money market mutual funds safer. On the contrary, the rule proposal would throw open the door to even riskier investment practices by money market mutual funds. We therefore urge the Commission to withdraw this proposal until it can come up with an alternative approach that both reduces reliance on ratings and appropriately minimizes the risks money market funds may assume.