Investment Company Act of 1940 — Rule 2a-7
Investment Company Institute — Request for Interpretation under Rule 2a 7
August 10, 2010
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
The Incoming Letter is in Acrobat format.