Thomas P. Vartanian, chair of Dechert LLP’s Financial Institutions practice, has sent a letter to the Financial Stability Oversight Council (FSOC) in regard to Treasury Secretary Geithner’s September 27, 2012 letter to members of the FSOC concerning recommendations for actions with regard to Money Market Funds (MMFs), including recommendations to the Securities and Exchange Commission (SEC) regarding reform of the MMF regulatory structure.

Dechert’s letter discusses a series of issues that the FSOC must consider in connection with any potential MMF recommendation:

- What internal agency rules will define the FSOC’s exercise of its section 120 authority to ensure the appropriateness of the process, and the absence of bias and predisposition of relevant issues?