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North Carolina INDEPENDENT Colleges & Universities
Barton College A. Hope Williams Wilson Resident Belmont Abbey College Belmont Bennett College for Women April 13, 2012 Greensboro Brevard College Brevard Cabarrus College of Health Sciences Concord Ms. Elizabeth M. Murphy RECEIVED Campbell University Secretary Buies Creek APR 19 »« Catawba College Securities and Exchange Commission Salisbury Chowan University 100 F Street, NE pa>pr?THESECRETARY| Murjreesboro Davidson College Washington, DC 20549-1090 Davidson Duke University Durham Dear Ms. Murphy: Elon University Elon Gardner-Webb University On behalf ofthe 36 independent colleges and universities within North Boiling Springs Greensboro College Carolina Independent Colleges and Universities (NCICU), I am writing about the Greensboro Guilford College proposal to amend Rule 2a-7. NCICU has serious questions about requiring a Greensboro High Point University floating NAV for money market mutual funds rather than a stable $1.00 per share High Point NAV. Such a change would be expensive from bdm the operational and Johnson C. Smith University Charlotte recordkeeping perspective. Lces-McRae College Banner lilk I^noir-Rhyne University Hickory Colleges and universities are among the many organizations that Livingstone College consistently use money market mutual funds as an efficient cash management Salisbury Louisburg College tool. We believe that requiring a floating NAV would be more burdensome and Louisburg Mars Hill College would force organizations to seek other products that might provide fewer Mars Hill benefits. Essentially we believe that requiring a floating NAV would eliminate Meredith College Raleigh money market mutual funds as a stable option and as a reasonable investment for Methodist University Fayetteville cash management purposes. Montreal College Montreal Mount Olive College NCICU believes regulation of all funds, including money market mutual Mount Olive N.C WcsleyanCollege funds, is important. However, moving to a floating NAV is likely to have Rocky Mount Pfcifler University significant unintended consequences that could eliminate the value ofinvesting in Misenheimer Queens University of Charlotte money market mutual funds in the manner as they currently are used by multiple Charlotte types of organizations including colleges and universities. St. Andrews University Laurinburg Saint Augustine's College Raleigh Thank you for the opportunity to comment on this important issue. Salem College Winston-Salem Shaw University Sincerely, Raleigh Wake Forest University Winston-Salem Warren Wilson College Asheville William Peace University Raleigh A. Hope Williams Wingate University Wingate
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530 N. Blount Street Raleigh, North Carolina 27604 Phone:(919)832-5817 Fax:(919)833-0794 www.ncicu.org