SEC Announces Implementation Schedule for New Money Market Fund Rules

As described in our Client Alert of January 28, 2010, the Securities and Exchange Commission (the "SEC") late last month approved significant new rules governing money market funds.  The new rules expand portfolio disclosure requirements and include a number of provisions intended to improve the liquidity and credit quality of money market fund assets and to reduce the risk that any fund's net asset value may sink below $1 per share. 

When the SEC announced its approval of the new rules last month it did not disclose when they would become effective.  The SEC recognized, however, that certain of the new rules impose significant new duties and/or investment restrictions on money market funds and indicated that different rules might become effective at different dates.  The SEC has now announced the specific implementation schedule for the new rules.  This Client Alert summarizes the more significant of the new rules (the summaries largely repeat our Client Alert of January 28, 2010) and sets forth each rule's effective date.

To read Orrick's client alert about the new money market fund rules, please click here.