EX-99.77D POLICIES 2 policychanges.txt POLICY CHANGES AllianceBernstein Exchange Reserves 811-08294 77.D-Investment Policy Changes Chart ALLIANCEBERNSTEIN EXCHANGE RESERVES FORMER POLICIES CURRENT POLICIES Investment Objective: Fundamental: Non-fundamental: The Fund's investment objective The Fund's investment is maximum current income to objective is maximum current the extent consistent with income to the extent safety of principal and consistent with safety liquidity. of principal and liquidity. Fundamental Investment Policies: The Fund may not invest 25% The Fund may not or more of its assets in the concentrate investments in an securities of issuers conducting industry, as concentration their principal business may be defined under the activities in any one industry; 1940 Act or the rules and provided that, for purposes of regulations thereunder (as such this restriction, there is no statute, rules or regulations may limitation with respect to be amended from time to time) or investments in securities by guidance regarding, issued or guaranteed by the interpretations of, or exemptive United States Government, its orders under, the 1940 Act or the agencies or instrumentalities rules or regulations thereunder or certificates of deposit published by appropriate and bankers' acceptances regulatory authorities. issued or guaranteed by, or interest-bearing savings deposits maintained at, banks and savings institutions and loan associations (including foreign branches of U.S. banks and U.S. branches of foreign banks). The Fund may not invest more The Fund is diversified as than 5% of its assets in the required by the 1940 Act or securities of any one issuer Rule 2a-7. (exclusive of securities issued or guaranteed by the United States Government, its agencies or instrumentalities), except that up to 25% of the value of the Fund's total assets may be invested without regard to such 5% limitation. (As a matter of operating policy, pursuant to Rule 2a-7, the Fund will invest no more than 5% of its assets in the first tier (as defined in Rule 2a-7) securities of any one issuer, except that under Rule 2a-7, the Fund may invest up to 25% of its total assets in the first tier securities of a single issuer for a period of up to three business days. Fundamental policy number (ii) would give the Fund the ability to invest, with respect to 25% of its assets, more than 5% of its assets, in any one issuer only in the event rule 2a-7 is amended in the future.) The Fund may not invest in more Restriction eliminated. than 10% of any one class of an issuer's outstanding securities (exclusive of securities issued or guaranteed by the United States Government, its agencies or instrumentalities). The Fund may not borrow money The Fund may not issue any except from banks on a senior security (as that term temporary basis or via entering is defined in the 1940 Act) into reverse repurchase or borrow money, except to the agreements in aggregate amounts extent permitted by the 1940 not to exceed 15% of the Fund's Act or the rules and assets and to be used regulations thereunder (as exclusively to facilitate the such statute, rules or orderly maturation and sale of regulations may be amended portfolio securities during any from time to time) or by periods of abnormally heavy guidance regarding, or redemption requests, if they interpretations of, or should occur; such borrowings exemptive orders under, the may not be used to purchase 1940 Act or the rules or investments and the Fund will regulations thereunder not purchase any investment published by appropriate while any such borrowings exist. regulatory authorities. For the purposes of this restriction, margin and collateral arrangements, including, for example, with respect to permitted borrowings, options, futures contracts, options on futures contracts and other derivatives such as swaps are not deemed to involve the issuance of a senior security. Related fundamental policy: Related fundamental policy: The Fund may not issue in Policy eliminated. senior securities except as See new fundamental policy above. permitted by the Act and interpretations thereunder. The Fund may not pledge, Restriction eliminated. hypothecate or in any manner transfer, as security for indebtedness, any securities owned or held by the Fund except as may be necessary in connection with any borrowing mentioned above, including reverse repurchase agreements, and in an aggregate amount not to exceed 15% of the Fund's assets. The Fund may not make loans, The Fund may not make loans provided that the Fund may except through (i) the purchase money market purchase of debt obligations securities and enter into in accordance with its repurchase agreements. investment objectives and policies; (ii) the lending of Fund securities; (iii) the use of repurchase agreements; or (iv) the making of loans to affiliated funds as permitted under the 1940 Act, the rules and regulations thereunder (as such statutes, rule or regulations may be amended from time to time), or by guidance regarding, and interpretations of, or exemptive orders under, the 1940 Act. The Fund may not make Prohibition eliminated. investments for the purpose of exercising control. The Fund may not purchase Policy eliminated. securities of other investment companies, except in connection with a merger, consolidation, acquisition or reorganization. Related non-fundamental policy: The Portfolio may invest in the securities of other investment companies, including exchange-related funds, to the extent permitted under the 1940 Act or the rules and regulations thereunder (as such statute, rules or regulations may be amended from time to time) or by guidance regarding, interpretations of, or exemptive orders under, the 1940 Act or the rules or regulations thereunder published by appropriate regulatory authorities. The Fund may not The Fund may not purchase invest in real estate or sell real estate except that (other than money market it may dispose of real securities secured by estate acquired as a result of real estate or interests the ownership of securities therein or money market or other instruments. This securities issued by restriction does not prohibit companies which invest the Fund from investing in in real estate, or securities or other instruments interests therein), backed by real estate or in commodities or commodity securities of companies engaged contracts, interests in the real estate business. in oil, gas and other mineral exploration or other development programs. The Fund may not Policy eliminated. purchase securities on margin. Related non-fundamental policy: The Fund may not purchase securities on margin, except (i) as otherwise provided under rules adopted by the SEC under the 1940 Act or by guidance regarding the 1940 Act, or interpretations thereof, and (ii) that the Fund may obtain such short-term credits as are necessary for the clearance of portfolio transactions, and the Fund may make margin payments in connection with futures contracts, options, forward contracts, swaps, caps, floors, collars and other financial instruments. The Fund may not make Prohibition eliminated. short sales of securities or maintain a short position or write, purchase or sell puts, calls, straddles, spreads or combinations thereof. The Fund may not invest Restriction eliminated. in securities of issuers (other than agencies and instrumentalities of the United States Government) having a record, together with predecessors, of less than three years of continuous operation if more than 5% of the Fund's assets would be invested in such securities. The Fund may not Restriction eliminated. purchase or retain securities of any issuers if those officers and trustees of the Fund and employees of Alliance who own individually more than 1/2 of 1% of the outstanding securities of such issuer together own more than 5% of the securities of such issuer. The Fund may not act as The Fund may not act as an an underwriter of securities. underwriter of securities, except that the Fund may acquire restricted securities under circumstances in which, if such securities were sold, the Fund might be deemed to be an underwriter for purposes of the Securities Act of 1933, as amended (the Securities Act).