Memo #
8593

INSTITUTE COMMENTS ON PROPOSED AMENDMENTS TO RULE 2A-7

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1 See Memorandum to Money Market Funds Advisory Committee No. 1-97 and SEC Rules Committee No. 5-97, dated January 15, 1997. January 27, 1997 TO: MONEY MARKET FUNDS ADVISORY COMMITTEE No. 3-97 SEC RULES COMMITTEE No. 10-97 RE: INSTITUTE COMMENTS ON PROPOSED AMENDMENTS TO RULE 2a-7 ______________________________________________________________________________ The Institute has filed the attached comment letter on the proposed technical amendments to Rule 2a-7 under the Investment Company Act, regulating money market funds. The Institutes letter is substantially similar to the draft letter previously circulated to you.1 The only significant difference is that the final letter suggests revised language for the condition in the definition of "collateralized fully," regarding the status of a repurchase agreement in the event of a counterparty bankruptcy, to more accurately reflect current insolvency law and procedures thereunder. Amy B.R. Lancellotta Associate Counsel Attachment (in .pdf format)

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