The New Era of Money Market Fund Regulation

Morgan Lewis
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On July 23, 2014, the U.S. Securities and Exchange Commission (SEC) voted 3–2 to significantly amend the regulatory framework of money market mutual funds (MMFs), particularly Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act).1 These changes come four years after the SEC last adopted several amendments to Rule 2a-7 and follow a lengthy debate surrounding MMF reform among regulators and industry participants. The amendments and related regulations will drastically alter the MMF industry and force MMFs and their boards of directors and advisers to make substantial changes to their product offerings, operations, and compliance processes.

The reforms can be grouped into four general categories, each of which is further discussed herein...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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