Investment Company Act of 1940 — Rule 2a-7
Investment Company Institute — Request for Interpretation under Rule 2a 7
August 10, 2010
Karrie McMillan
General Counsel
Investment Company Institute
1401 H Street, NW
Washington, DC 20005-2148
Re: Investment Company Institute — Request for Interpretation under Rule 2a 7
Dear Ms. McMillan:
Based on the analysis set forth in your letter of August 10, 2010, we agree that for purposes of calculating a money market fund's weighted average portfolio maturity under rule 2a 7(c)(2)(iii) under the Investment Company Act of 1940, a money market fund may treat a short-term floating rate security that is subject to a demand feature as having a maturity equal to the period remaining until the principal can be recovered through demand.
Very truly yours,
Adam B. Glazer
Senior Counsel
Incoming Letter
The Incoming Letter is in Acrobat format.
http://www.sec.gov/divisions/investment/noaction/2010/ici081010.htm
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