August 23, 1991
TO: MONEY MARKET FUNDS AD HOC COMMITTEE NO. 22-91
RE: INTERPRETIVE ISSUES AND TECHNICAL QUESTIONS UNDER RULE 2a-7
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As you may recall, after the Commission adopted the
amendments to Rule 2a-7 last February the Institute inquired
whether any firms had technical questions or interpretive issues
under the Rule that we should raise with the SEC staff. At that
time, the amendments to the Rule had not yet become effective
and, as we only heard from a few firms, we decided not to
approach the staff until experience was gained under the amended
Rule.
In a recent conversation with a member of the SEC staff
about Rule 2a-7, the staff member suggested that the Institute
submit to them any interpretive issues or technical questions
that have arisen under the Rule. The staff then would consider
addressing them in the release that it anticipates will be issued
regarding the regulation of tax-exempt money market funds. (We
do not know when the staff expects such a release to be issued,
or even if such a release definitely will be issued.)
Therefore, if your firm has encountered any interpretive
issues or technical questions in connection with Rule 2a-7 that
you have not already communicated to us and that you would like
the staff to address, please provide them to me in writing by
September 25, 1991. They may be faxed to me at 202/659-1519.
Amy B.R. Lancellotta
Assistant General Counsel