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Vanguard's Initial Objection.pdf

s71908-1.pdf

🔗 Source: sec.gov

📊 Size: 188 KB

👤 Author: John J. Brennan

⬇️ Downloads: 245

Summary

The Vanguard Group opposes the SEC's proposal to eliminate references to credit ratings in Rule 2a-7, which has provided a strong regulatory framework for money market funds for 25 years. Vanguard believes that removing NRSRO ratings would weaken investment standards, pose a risk to the stability of the $3.5 trillion money market fund industry, and remove an important investor protection. NRSRO ratings provide an independently established baseline for money market fund investments and are a valuable assurance to investors that investments are not subject to unnecessary risks. Vanguard supports the SEC's efforts to address the root problems of flawed ratings, but believes that eliminating NRSRO ratings from Rule 2a-7 is not the solution. Instead, the company suggests that the SEC should focus on improving the quality and transparency of NRSRO ratings, and ensuring that fund managers and boards of directors adhere to the "minimal credit risk" standard in Rule 2a-7.

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Description

The Vanguard Group opposes the SEC's proposal to eliminate references to credit ratings in Rule 2a-7, which has provided a strong regulatory framework for...

Technical Information

File Format: PDF
File Size: 188 KB
Pages: 4
Language: EN
Author: John J. Brennan
Total Downloads: 245
Last Updated: 2 weeks ago

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