RegAlert1994-07-01
Added · Updated
SEC Division of Investment Management staff letter: J.P. Morgan Structured Obligations Corporation
The Division of Investment Management declines to provide assurance that purchasers of certain asset-backed securities issued by J.P. Morgan Structured Obligations Corporation may treat them as Government Securities under Rule 2a-7(d)(1) of the Investment Company Act of 1940. The Division determined that the Notes present credit risks significantly different from direct investments in Government Securities due to the reliance on a Swap Counterparty and the requirement for daily collateral adjustments. Consequently, money market funds investing in these Notes must analyze the specific credit risks associated with the Trust and the Swap Counterparty rather than treating the instruments as equivalent to Government obligations.
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2'1 JUl1994
Our Ref. No. 94-277-CC
J. P. Morgan Structured
RESPONSE OF THE DIVISION Obligations Corporation
OF INVESTMENT MANAGEMENT File No. 132-3
Your letter of April 15, 1994 requests assurance that the
Division of Investment Management would not recommend enforcement
action to the Securities and Exchange Commission if purchasers of
certain series of notes described below ("Notes") treat them as
instruments issued or guaranteed by the United States Government
or an agency thereof ("Government Securities") for purposes of
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