SEC Division of Investment Management staff letter: Federated Municipal Funds

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Investment Company Act of 1940-Section 17(a)(l), Rule 17a-7 Douglas J. Scheidt, Esquire Chief Counsel and Associate Director Division of Investment Management U.S. Securities and Exchange Commission 100F Street, N.E. Washington, D.C. 20549 Re: Federated Municipal Funds - Rule 17a-7 Dear Mr. Scheidt:
We are writing on behalf of certain investment companies advised by Federated Investment Management Company (together with other commonly controlled investment advisers, "Federated") that invest, or one or more series of which invest, primarily in municipal securities, i.e., securities issued by state and local governments (the "Municipal Funds"). 1 The Municipal Funds hereby request that the staff (the "Staff ') of the Securities and Exchange Commission (the "Commission" or the "SEC") extend the no-action position that it took in the 1995United Municipal Bond Fund no-action letter to address the use of Standard & Poor's SecuritiesEvaluations, Inc., an independent pricing service ("SPSE), in connection with certain transactions under Rule 17a-7 under the Investment Company Act of 1940, as amended (the "1940 Act"). 1 The Municipal Funds currently include the following open and closed-end management investment companiesregistered with the Commission: Cash Trust Series 11, Cash Trust Series, Inc., Federated Fixed Income Securities, Inc., Federated Income SecuritiesTrust, Federated Intermediate Premier Municipal Income Fund, Federated Municipal High Yield Advantage Fund, Inc., Federated Municipal Securities Fund, Inc., Federated Municipal Securities Income Trust, Federated Premier Municipal Income Fund, Federated Short-Tenn Municipal Trust, IntermediateMunicipal Trust and Money Market Obligations Trust. Federated would also rely on the Staffs interpretive opinion with respect to any additional investment companies that retain Federated as an investment adviser (as defined in Section 2(a)(20) of the 1940 Act) to manage a portfolio invested primarily in municipal securities. NEW YORK * LONDON * LOS ANGELES + PARIS t SAN FRANCISCOWASHINGTON, D.C. * PHILADELPHIA * PITTSBURGHt OAKLAND MUNICH + PRINCETON * NORTHERNVIRGINIA WILMINGTON NEWARK MIDLANDS, U.K. * CENTURY CITY + RICHMOND reedsmith.com