FSOC – Proposed Recommendations Regarding Money Market Mutual Fund Reform (Docket Number FSOC -2012-0003) – Alternative Three: NAV Buffer

We are writing in response to the Financial Stability Oversight Council’s (the Council) recommendations on money market mutual fund (MMF) reform, “Proposed Recommendations Regarding Money Market Mutual Fund Reform” (“the Proposal(s)”). Treasury Strategies, Inc. has prepared the following opinion regarding the Council’s recommendation that MMFs be required to establish a risk-based NAV buffer.