Both the President's Working Group on Financial Markets and the Financial Stability Oversight Council have consistently called for the SEC to pursue additional reforms to address structural vulnerabilities in [money market funds], including unanimous recommendations in the [FSOC's] 2011 and 2012 annual reports. The Dodd-Frank Wall Street Reform and Consumer Protection Act gives the Council both the responsibility and the authority to take action to address risks to financial stability if an agency fails to do so.  (emphasis added) Accordingly, I would like the [FSOC] to consider taking a series of steps to address this challenge. With Treasury Secretary Timothy Geithner and the Financial Stability Oversight Council taking the lead on further reforms to money market mutual funds, Geithner and the FSOC will be testing the limits of the super-regulatory powers granted by the Dodd-Frank Act.  Section 12(a)(1) of the Dodd-Frank Act set forth the essential duties and powers of the FSOC. Among these are: identifing systemically important financial market utilities and payment, clearing, and settlement activities (as that term is defined in title VIII); and making recommendations to primary financial regulatory agencies to apply new or heightened standards and safeguards for financial activities or practices that could create or increase risks of significant liquidity, credit, or other problems spreading among bank holding companies, nonbank financial companies, and United States financial markets. As his September 27, 2012 letter to the FSOC makes clear, Geithner intends for the FSOC to use its Section 12(a)(1) power to bring money market funds into the ambit of the Dodd-Frank Act by declaring them systematically important nonbank financial companies.