March 15, 1993
TO: MONEY MARKET FUNDS AD HOC COMMITTEE NO. 2-93
SECONDARY MARKET DISCLOSURE TASK FORCE
RE: APRIL 7 MEETING
__________________________________________________________
The Institute has scheduled a joint meeting of the Money
Market Funds Ad Hoc Committee and the Secondary Market Disclosure
Task Force for April 7, 1993 at 10:00 a.m. at the Institute.
Lunch be served following the meeting. For your information, a
meeting of the Derivative Instruments Subcommittee focusing on
mutual funds' use of swaps will be held that afternoon beginning
at 2:00 p.m., which you are invited to attend.
At the April 7th meeting, we will discuss Commissioner
Roberts' suggestion to amend Rule 2a-7 to address problems in
obtaining secondary market disclosure for tax-exempt instruments
(see Appendix A) and the draft disclosure guidelines for tax-
exempt money market funds prepared by members of the Task Force,
which we had previously circulated (see Memorandum to Money
Market Funds Ad Hoc Committee No. 8-92 and Secondary Market
Disclosure Task Force dated July 14, 1992). A revised copy of
the draft guidelines will be circulated shortly before the
meeting.
In addition, we will discuss issues arising from the
staff's letter on technical issues under Rule 2a-7 relating to
the treatment and analysis of variable rate demand notes subject
to conditional guarantees under paragraph (c)(3)(ii) of the Rule
(a copy of which is attached as Appendix B); the appropriateness
of several new instruments that recently have been marketed to
money market funds; and, the discussion in the staff's recent
generic comment letter and Morgan Keegen no action letter
concerning the treatment of capped floaters under paragraph
(d)(1) of Rule 2a-7 (copies of which are attached as Appendix C).
If there are any other items that you would like to discuss
at the meeting, please let me know by April 1. My direct number
is 202/955-3523.
* * *
Please indicate on the attached form whether you plan to
attend the April 7th Money Market Fund Ad Hoc Committee and
Secondary Market Disclosure Task Force Meeting, and whether you
will be staying for the Derivative Instruments Subcommittee
Meeting. Please return the form by mail to Laura Pawlowski,
Investment Company Institute, 1600 M Street, N.W., Washington,
D.C. 20036 or by fax (202/659-1519) by April 1, 1993.
Amy B.R. Lancellotta
Associate Counsel
Attachments