RegAlert2010-08-19
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SEC Division of Investment Management staff letter: Investment Company Institute Designated NRSROs
The Division of Investment Management will not recommend enforcement if money market fund boards do not designate nationally recognized statistical rating organizations (NRSROs) or make related disclosures before the Commission completes its review of rule 2a-7 under section 939A of the Dodd-Frank Act. Until the Commission modifies rule 2a-7 in accordance with the Act, money market funds relying on this letter must continue to comply with the obligations for determining and monitoring eligible securities as in effect before May 5, 2010, excluding the rescinded limitation on holding unrated asset-backed securities.
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Investment Company Act of 1940 — Section 2(a)(41) and Rules 2a-4 and 22c-1 Investment Company Institute Designated NRSROs
August 19, 2010
Karrie McMillan General Counsel Investment Company Institute 1401 H Street, NW Washington, DC 20005-2148
Dear Ms. McMillan:
As you know, the amendments to rule 2a-7 under the Investment Company Act of 1940 that the Commission adopted last February require boards of directors of money market funds to designate at least four nationally recognized statistical rating organizations (“NRSROs”) whose ratings the fund would use to determine the eligibility of portfolio securities under the rule. The rule also requires funds to disclose designated NRSROs in their statements of additional information. In order to meet the December 31, 2010 compliance date, boards of directors will likely have to designate NRSROs no later than the Fall of this year.
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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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