On November 13, 2012, the members of the Financial Stability Oversight Council (“FSOC”) voted unanimously to advance for public comment Proposed Recommendations Regarding Money Market Reform (“Proposed Recommendations”). The Proposed Recommendations generally incorporate the major components of the reforms that were anticipated to be proposed by the SEC in a hearing that was scheduled to occur in August. The FSOC’s action was prompted by the announcement by SEC Chairman Mary Shapiro that the SEC would not proceed with a vote to publish a notice of proposed rulemaking on such a proposal due to a lack of sufficient support among SEC Commissioners. The Proposed Recommendations put forward the following three potential areas for reform...
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