There are important changes to Rule 2a-7, Form N-MFP and Form N-CR that go into effect on April 14, 2016, and have nothing to do with fees, gates, retail shareholders or floating NAVs. At this point, every fund should be prepared to submit revised procedures to its board of directors for review. If you’re running … Continue Reading
Yesterday, the SEC adopted what I hope will be the final amendments to Rule 2a-7 made during my career. For the first time in the history of Rule 2a-7, the SEC cut more than it added, reducing the length of the rule by over 12%. The amendments relate primarily to credit and diversification requirements, but … Continue Reading
This is the second installment of my review of the update to the 2014 Money Market Fund Reform Frequently Asked Questions (the “FAQs”) released on August 4th. This post will explain a new FAQ that addresses whether gating a fund represents an “emergency.”… Continue Reading
On August 4, the staff of the Division of Investment Management updated their 2014 Money Market Fund Reform Frequently Asked Questions (the “FAQs”). I’ll discuss these revisions in a series of posts, starting with an important question relating to beneficial ownership by natural persons.… Continue Reading
