On June 5, 2013, the U.S. Securities and Exchange Commission (the SEC) released for public comment its proposal to further reform the regulatory structure governing money market funds and address the perceived systemic risks money market funds present. The SEC’s proposed reform package includes two alternative approaches to reform that could be adopted by the SEC either alone or in combination:

1. a requirement that institutional prime money market funds (institutional prime funds) transact at a floating net asset value (NAV) per share, as opposed to a stable NAV per share of $1.00, while permitting retail prime money market funds (retail prime funds) and government money market funds (government funds) to continue to transact at a stable NAV per share (the Floating NAV Alternative)...