On June 11, 2008, the Securities and Exchange Commission (the “SEC”) approved the initial two of three sets of proposed amendments relating to the use of Nationally Recognized Statistical Rating Organizations (“NRSROs”) in the SEC’s rules and forms. In general, these first two proposed amendments are designed to avoid conflicts of interest and increase transparency in the credit rating

process. A copy of the SEC release that sets forth the first two amendments can be viewed at

http://sec.gov/rules/proposed/2008/34-57967.pdf. (For more information, see the July 2, 2008 Capital Markets and Securities Law News Bulletin.)

See this alert for more information.

On June 25, 2008, the SEC approved the third set of proposed amendments, which would amend four rules under the Investment Company Act of 1940 (the “1940 Act”) and one rule under the Investment Advisers Act of 1940 (the “Proposed Amendments”). A copy of the Proposed

Amendments can be viewed at http://www.sec.gov/rules/proposed/2008/ic-28327.pdf. This Client Alert describes the proposed changes to Rule 2a-7 under the 1940 Act and briefly summarizes the potential impact of the Proposed Amendments on the regulation of money market funds.