Money Market Fund Compliance & Resources

Rule 2a-7 is one of the longest and most complicated regulations promulgated under the Investment Company Act. Reading the text of the rule may raise more questions than it answers. Interpreting Rule 2a-7 often requires an in-depth understanding of the history and purpose of the rule, as well as the structure and trading of money market instruments. The Investment Management Group is dedicated to developing a common understanding of Rule 2a-7 among money market fund managers and those who deal with money market funds.

Here you will find a wide range of materials to assist in-house attorneys, compliance officers, portfolio managers, investment analysts, traders, and others in understanding and interpreting Rule 2a-7. The materials range from quick-reference tables and charts, to in-depth analyses of specific provisions. These materials should provide the answers to any routine, and much non-routine, questions about Rule 2a-7. Specific questions include:

• What is an “Eligible Security” under Rule 2a-7? 
• How do you calculate a security’s remaining maturity under Rule 2a-7? 
• What are the investment limitations imposed by the diversification requirements of Rule 2a-7? 
• What is required to determine whether a security has minimal credit risks? 
• When is a security “U.S. Dollar denominated” for purposes of Rule 2a-7? 
• What must you do when a portfolio security is downgraded or is no longer an Eligible Security? 
• What must you do when a portfolio security defaults? 
• What must you do if the shadow NAV deviates from the amortized cost value by more than 1/2 of a cent?

Quick Reference Tables:

• Maturity of Variable and Floating Rate Securities
• First Tier and Second Tier Ratings 
• Issuer Diversification 
• Enhancer Diversification 
• Five Steps to Diversification

If you cannot find the answer to your question in these materials, your question to our experts.

Other materials:

• Observations on the SEC’s Latest Approach to Money Market Reform
• FSOC and Money Market Fund Reform: A Path to Nowhere
• Be Wary When Someone Asks You To Certify in Writing That You Cannot Trust a Word They’ve Said
• Treatment of Potential Moody's Downgrades under Rule 2a-7 Don't let Disjunctives Lead to Dysfunction
• Complete Rule 2a-7 Manual 
• Events Requiring Action by a Money Market Fund 
• Recent Repo Developments 
• What Way Should a Fund Value Guarantees and Demand Features for Purposes of Enhancer Diversification