To read this content please select one of the options below:

US SEC approves sweeping amendments to rules governing money market funds

Jack Murphy (Dechert LLP, Washington, D.C. USA)
Stephen Cohen (Dechert LLP, Washington, D.C. USA)
Brenden Carroll (Dechert LLP, Washington D.C. USA)
Aline A. Smith (Dechert LLP, Washington D.C. USA)
Matthew Virag (Dechert LLP, New York, New York, USA)
Justin Goldberg (Dechert LLP, Irvine, California, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 5 May 2015

275

Abstract

Purpose

To explain the background and details and to discuss the implications of the USA Securities and Exchange Commission’s (SEC’s) July 23, 2014 amendments to Rule 2a-7 and other rules that govern money market funds under the Investment Company Act of 1940.

Design/methodology/approach

Explains the background, including problems during the financial crisis, the USA Treasury’s temporary guarantee program in 2008, earlier SEC proposals, and the USA Financial Stability Oversight Council’s recommendations. Details the amendments to Rule 2a-7, including the authorization to impose liquidity fees and redemption gates, the floating net asset value (NAV) requirement, the impact of the amendments on unregistered money funds operating under Rule 12d1-1, guidance on fund valuation methods, disclosure requirements, requirements for money fund portfolios to be diversified as to issuers of securities and guarantors, stress testing requirements, and compliance dates.

Findings

The Amendments set forth sweeping changes to money fund regulation and will have a profound effect on the money fund industry. Although the most significant provisions of the Amendments – the floating NAV requirement and the imposition of liquidity fees and redemption gates – will not go into effect for two years, the changes to the industry will be apparent almost immediately.

Practical implications

Money fund managers and boards of directors should begin assessing the potential impact of the Amendments and develop a schedule to come into compliance.

Originality/value

Practical guidance from experienced financial services lawyers.

Keywords

Acknowledgements

© 2015 Dechert LLP

Disclaimer. All rights reserved. This publication should not be considered as legal opinions on specific facts or as a substitute for legal counsel. It is provided by Dechert LLP as a general informational service and may be considered attorney advertising in some jurisdictions. Prior results do not guarantee a similar outcome.

IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

Citation

Murphy, J., Cohen, S., Carroll, B., Smith, A.A., Virag, M. and Goldberg, J. (2015), "US SEC approves sweeping amendments to rules governing money market funds", Journal of Investment Compliance, Vol. 16 No. 1, pp. 25-39. https://doi.org/10.1108/JOIC-01-2015-0016

Publisher

:

Emerald Group Publishing Limited

Copyright © 2015, Authors

Related articles