Notice of Proposed Exemptive Order Granting Permanent Exemptions Under the Securities Exchange Act of 1934 From the Confirmation Requirements of Exchange Act Rule 10b-10 for Certain Money Market Funds, 44076-44078 [2014-17748]
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44076
Federal Register / Vol. 79, No. 145 / Tuesday, July 29, 2014 / Notices
The Commission believes that the
Exchanges have satisfied each of these
conditions. The Commission also
believes that granting the Exchanges an
exemption from the rule filing
requirements under Section 19(b) of the
Exchange Act will promote efficient use
of Commission and the Exchanges’
resources by avoiding duplicative rule
filings based on simultaneous changes
to identical rule text sought by BX,
NASDAQ, and PHLX.14 The
Commission therefore finds it
appropriate in the public interest and
consistent with the protection of
investors to exempt the Exchanges from
the rule filing requirements under
Section 19(b) of the Exchange Act with
respect to the above-described rules
they have incorporated by reference.
This exemption is conditioned upon the
Exchanges promptly providing written
notice to their BX Options Participants
and NOM Participants, respectively,
whenever PHLX changes a rule that they
have incorporated by reference.
Accordingly, it is ordered, pursuant to
Section 36 of the Exchange Act,15 that
the Exchanges are exempt from the rule
filing requirements of Section 19(b) of
the Exchange Act solely with respect to
changes to the rules identified in their
requests that incorporate by reference
certain PHLX rules that are the result of
changes to such PHLX rules, provided
that the Exchanges promptly provide
written notice to their BX Options
Participants and NOM Participants,
respectively, whenever PHLX proposes
to change a rule that the Exchanges have
incorporated by reference.
SECURITIES AND EXCHANGE
COMMISSION
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.16
Kevin M. O’Neill,
Deputy Secretary.
Electronic Comments
[FR Doc. 2014–17638 Filed 7–28–14; 8:45 am]
BILLING CODE 8011–01–P
[Release No. 34–72658; File No. S7–08–14]
Notice of Proposed Exemptive Order
Granting Permanent Exemptions
Under the Securities Exchange Act of
1934 From the Confirmation
Requirements of Exchange Act Rule
10b–10 for Certain Money Market
Funds
July 23, 2014.
Securities and Exchange
Commission.
ACTION: Notice of Proposed Exemptive
Order; Request for Comment.
AGENCY:
Pursuant to Section 36 of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) and Exchange Act
Rule 10b–10(f), the Securities and
Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) is proposing to grant
exemptive relief, subject to certain
conditions, from the immediate
confirmation delivery requirements of
Exchange Act Rule 10b–10 for
transactions effected in shares of any
open-end management investment
company registered under the
Investment Company Act of 1940
(‘‘Investment Company Act’’) that holds
itself out as a money market fund
operating in accordance with Rule 2a–
7(c)(1)(ii) of the Investment Company
Act.
SUMMARY:
Comments must be received on
or before August 19, 2014.
ADDRESSES: Comments may be
submitted by any of the following
methods:
DATES:
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/other.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number S7–
08–14 on the subject line; or
• Use the Federal Rulemaking Portal
(https://www.regulations.gov). Follow the
instructions for submitting comments.
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Paper Comments
14 See BATS Options Market Order, supra note
11, 75 FR at 8761; see also 2004 Order, supra note
13, 69 FR at 8502.
15 15 U.S.C. 78mm.
16 17 CFR 200.30–3(a)(76).
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• Send paper comments in triplicate
to Kevin M. O’Neill, Deputy Secretary,
Securities and Exchange Commission,
100 F Street NE., Washington, DC
20549–1090.
All submissions should refer to File
Number S7–08–14. This file number
should be included on the subject line
if email is used. To help us process and
review your comments more efficiently,
please use only one method. The
Commission will post all comments on
the Commission’s Internet Web site
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(https://www.sec/gov/rules/other.shtml).
Comments are also available for Web
site viewing and printing in the
Commission’s Public Reference Room,
100 F Street NE., Washington DC 20549,
on official business days between the
hours of 10:00 a.m. and 3:00 p.m. All
comments received will be posted
without charge; the Commission does
not edit personal identifying
information from submissions. You
should only submit information that
you wish to make publicly available.
FOR FURTHER INFORMATION CONTACT:
Natasha Vij Greiner, Branch Chief,
Jonathan C. Shapiro, Attorney-Adviser,
George Makris, Attorney-Adviser, at
202–551–5550, Division of Trading and
Markets, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–7010.
I. Background
Exchange Act Rule 10b–10 addresses
broker-dealers’ obligations to confirm
their customers’ securities transactions.1
Under Rule 10b–10(a), a broker-dealer
generally must provide customers with
information relating to their investment
decisions at or before the completion of
a securities transaction.2 Rule 10b–
10(b), however, provides an exception
for certain transactions in money market
funds that attempt to maintain a stable
net asset value (‘‘NAV’’) and where no
sales load or redemption fee is charged.3
The exception permits broker-dealers to
provide transaction information to
money market fund shareholders on a
monthly basis (subject to certain
conditions set forth in Rule 10b–10(b)(2)
and (3)) in lieu of immediate
confirmations for all purchases and
redemptions of shares of such funds.4
1 17
CFR 240.10b–10.
CFR 240.10b–10(a).
3 17 CFR 240.10b–10(b).
4 With respect to such money market funds,
Exchange Act Rule 10b–10(b)(2) requires a brokerdealer to give or send to a customer within five
business days after the end of each monthly period
a written statement disclosing, each purchase or
redemption, effected for or with, and each dividend
or distribution credited to or reinvested for, the
account of such customer during the month; the
date of such transaction; the identity, number, and
price of any securities purchased or redeemed by
such customer in each such transaction; the total
number of shares of such securities in such
customer’s account; any remuneration received or
to be received by the broker or dealer in connection
therewith; and that any other information required
by Rule 10b–10(a) will be furnished upon written
request: Provided, however, that the written
statement may be delivered to some other person
designated by the customer for distribution to the
customer. 17 CFR 240.10b–10(b)(2). Exchange Act
Rule 10b–10(b)(3) requires that such customer is
provided with prior notification in writing
disclosing the intention to send the written
information referred to in Rule 10b–10(b)(1) in lieu
of an immediate confirmation. 17 CFR 240.10b–
10(b)(3).
2 17
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Accordingly, customers historically
have received information for their
transactions in shares of money market
funds on a monthly basis.
Today, the Commission adopted
amendments to Rule 2a–7 of the
Investment Company Act. Among other
things, the amendments require
institutional prime money market funds,
which, under the prior rule, were
permitted to maintain a stable net asset
value, to sell and redeem shares based
on the current market-based value of the
securities held in their portfolios, i.e.,
transact at a ‘‘floating’’ NAV.5 As a
result, institutional prime money market
funds, like other mutual funds, will now
be required to value their portfolio
securities using market-based factors
(rather than amortized cost) and sell and
redeem shares at prices rounded to the
fourth decimal place (rather than
rounded to the nearest penny).6
However, institutional prime money
market funds will continue to be subject
to the ‘‘risk limiting’’ provisions of Rule
2a–7 and therefore will continue to be
limited to investing in short-term, highquality, dollar-denominated
instruments.7
Given that share prices of such
institutional prime money market funds
likely will fluctuate under the amended
rule, absent exemptive relief, brokerdealers will not be able to continue to
rely on the current exception under
Rule 10b–10(b) for transactions in
money market funds operating in
accordance with Rule 2a–7(c)(1)(ii).8
Instead, broker-dealers will be required
to provide immediate confirmations for
all such transactions.
5 See Money Market Fund Reform; Amendments
to Form PF, Securities Act Release No. 9616,
Investment Advisers Act Release No. 3879,
Investment Company Act Release No. 31166, at
section III.B (July 23, 2014) (‘‘Money Market Fund
Reform Adopting Release’’).
6 Id.; Investment Company Act Rule 2a–7(c)(1)(ii),
17 CFR 270.2a–7(c)(1)(ii).
7 Money Market Fund Reform Adopting Release,
at 143; see also Investment Company Act Rule 2a–
7(d), 17 CFR 270.2a–7(d) (risk-limiting conditions).
8 See generally Money Market Fund Reform;
Amendments to Form PF, Securities Act Release
No. 9408, Investment Advisers Act Release No.
3616, Investment Company Act Release No. 30551
(June 5, 2013), 78 FR 36834, 36934 (June 19, 2013);
see also Exchange Act Rule 10b–10(b)(1), 17 CFR
240.10b–10(b)(1) (limiting alternative monthly
reporting to money market funds that attempt to
maintain a stable net asset value).
As adopted, government and retail money market
funds are exempt from the Investment Company
Act Rule 2a–7(c)(1)(ii) floating NAV requirement,
and therefore, will continue to maintain a stable
NAV. See Money Market Fund Reform Adopting
Release, at sections III.C.1 and III.C.2. Accordingly,
for investor transactions in such exempt funds,
broker-dealers would continue to qualify under the
exception under Rule 10b–10 and be permitted to
send monthly transaction reports.
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In the money market fund reform
proposing release,9 the Commission
requested comment on whether, if the
Commission adopted the floating NAV
requirement, broker-dealers should be
required to provide immediate
confirmations to all institutional prime
money market fund investors.
Commenters generally urged the
Commission not to impose such a
requirement, arguing that there would
be significant costs associated with
broker-dealers providing immediate
confirmations.10 Such costs are
expected to include both (1) the ongoing
costs of creating and sending trade-bytrade confirmations and (2) the costs of
implementing new systems to generate
confirmations.11 The Commission
recognizes that there may be costs
associated with requiring immediate
confirmations for such transactions,12
and is aware that such costs may be
passed on to investors in funds subject
to the floating NAV requirements.13
Nonetheless, given that institutional
prime money market funds likely will
fluctuate in price, some investors may
find value in receiving information
relating to their investment decisions at
or before the completion of a securities
transaction. The Commission requests
9 Money Market Fund Reform; Amendments to
Form PF, 78 FR 36934.
10 See Letter from Paul Schott Stevens, President
and CEO, Investment Company Institute, to
Elizabeth M. Murphy, Secretary, Commission, dated
September 17, 2013 (‘‘Investment Company
Institute Letter’’), at 37, available at https://
www.sec.gov/comments/s7-03-13/s70313-200.pdf;
Letter from Timothy W. Cameron, Managing
Director, SIFMA Asset Management Group, John
Maurello, Managing Director, SIFMA Private Client
Group, Matthew J. Nevins, Managing Director and
Associate General Counsel, SIFMA Asset
Management Group, dated Sept. 17, 2013 (‘‘9/17/13
SIFMA Letter’’), at Appendices 1 and 2, available
at https://www.sec.gov/comments/s7-03-13/s70313199.pdf; Letter from J. Charles Cardona, President,
The Dreyfus Corporation, to Elizabeth M. Murphy,
Secretary, Commission, dated September 17, 2013
(‘‘Dreyfus Letter’’), at 35, available at https://
www.sec.gov/comments/s7-03-13/s70313-167.pdf;
Letter from John D. Hawke, Jr., Arnold & Porter, on
behalf of Federated Investors, Inc. and its
subsidiaries, to Chair Mary Jo White, Commission,
dated September 17, 2013 (‘‘Federated Letter’’), at
22, available at https://www.sec.gov/comments/s703-13/s70313-225.pdf; Letter from Anthony J.
Carfang, Partner, Cathryn R. Gregg, Partner, Paul
LaRock, Principal, Steven Wiley, Manager, Treasury
Strategies, Inc., to Elizabeth M. Murphy, Secretary,
Commission, dated September 12, 2013 (‘‘Treasury
Strategies Letter’’), available at https://www.sec.gov/
comments/s7-03-13/s70313-118.pdf.
11 See, e.g., Federated Letter, at 22.
12 Money Market Fund Reform Adopting Release,
at section III.B.7.
13 See, e.g., Dreyfus Letter, at 35 (‘‘Confirming
transactions in [variable net asset value money
market mutual funds] on a transaction basis will
increase costs, which will be passed on to [money
market mutual fund] investors or underwriters.’’).
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44077
comments regarding these potential
benefits.
II. Discussion of Proposed Relief
After careful consideration, the
Commission is proposing to grant
exemptive relief pursuant to Section 36
of the Exchange Act 14 and Exchange
Act Rule 10b–10(f) 15 that would allow
broker-dealers, subject to certain
conditions, to provide transaction
information to investors in any money
market fund operating pursuant to Rule
2a–7(c)(1)(ii) on a monthly basis in lieu
of providing immediate confirmations.
The floating NAV requirement, as
adopted, only applies to institutional
prime money market funds—not to
government or retail money market
funds.16 Shareholders that invest in
institutional prime money market funds
will continue to have extensive investor
protections separate and apart from the
protections provided under Exchange
Act Rule 10b–10. For example, as stated
above, funds subject to the floating NAV
requirement will continue to be subject
to the ‘‘risk limiting’’ conditions of Rule
2a–7.17 These conditions limit the risk
in a money market fund’s portfolio by
governing the credit quality, liquidity,
diversification, and maturity of money
market investments. Accordingly,
mutual funds that hold themselves out
as money market funds—including
institutional prime money market
funds—may acquire only investments
that are short-term, high-quality, dollardenominated instruments.18
14 Section 36 of the Exchange Act authorizes the
Commission to conditionally or unconditionally
exempt any person, security, or transaction, or any
class or classes of persons, securities, or
transactions, from certain provisions of the
Exchange Act or certain rules or regulations
thereunder, by rule, regulation, or order, to the
extent that such exemption is necessary or
appropriate in the public interest, and is consistent
with the protection of investors. 15 U.S.C. 78mm.
15 Exchange Act Rule 10b–10(f) specifies the
Commission may conditionally or unconditionally
exempt any broker or dealer from the requirements
of Rule 10b–10(a) and Rule 10b–10(b) with regard
to specific transactions or specific classes of
transactions for which the broker or dealer will
provide alternative procedures to effect the
purposes of the rule. 17 CFR 240.10b–10(f).
16 See Investment Company Act Rule 2a–
7(c)(1)(ii), 17 CFR 270.2a–7(c)(1)(ii). As defined in
Investment Company Act Rule 2a–7(a)(25), as
amended, a retail money market fund is defined as
a money market fund that has policies and
procedures reasonably designed to limit all
beneficial owners of the fund to natural persons. 17
CFR 270.2a–7(a)(25). Under Rule 2a–7(a)(16), a
government money market fund is defined as a
money market fund that invests 99.5 percent or
more of its total assets in cash, government
securities, and/or repurchase agreements that are
collateralized fully. 17 CFR 270.2a–7(a)(16).
17 See Investment Company Act Rule 2a–7(d), 17
CFR 270.2a–7(d) (risk-limiting conditions).
18 Id.; see also Money Market Fund Reform
Adopting Release, at 143.
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While institutional prime money
market fund shares will fluctuate, they
are not likely to fluctuate daily,
primarily due to the high quality and
short duration of such funds’ underlying
portfolio securities.19 In addition, the
Commission anticipates that
information on prices will be available
through other means.20 For example,
under the new fund disclosure
requirements of Investment Company
Act Rule 2a–7(h)(10)(iii), investors—
including institutional investors—will
be able to access a fund’s daily mark-tomarket NAV per share on a money
market fund’s Web site.21 Moreover, as
previously noted, commenters raised
concerns about the costs associated with
requiring immediate confirmation for
such transactions, which, to some
extent, may be passed on to investors.22
Under Exchange Act Rule 10b–10(b),
the exemption from providing
immediate confirmations consistent
with the written notification
requirements under Rule 10b–10(a) is
subject to certain conditions.23 The
Commission preliminarily believes that
these conditions are also appropriate for
institutional prime money market funds
subject to the floating NAV requirement
under Rule 2a–7(c)(1)(ii) in order to
provide customers with consistent
information for all money market fund
transactions.
Given that there will be price
fluctuations in institutional prime
money market funds, the Commission
preliminarily believes that it may be
necessary or appropriate in the public
interest and consistent with the
protection of investors to also require
that broker-dealers provide immediate
confirmations upon a customer’s
request. Accordingly, to be eligible for
the exemption from Rule 10b–10(a), the
Commission proposes an additional
condition beyond those in place
pursuant to Rule 10b–10(b).
Specifically, the Commission proposes
that, to be exempt from the immediate
confirmation requirements of Rule 10b–
19 Id., at 155 n.491. Based on staff analysis of
Form N–MFP data between November 2010 and
November 2013, 53% of money market funds would
have fluctuated in price over a twelve-month period
with an NAV priced using basis point rounding,
compared with less than 5% of money market funds
that would have fluctuated in price using 10 basis
point rounding. Id., at 158–59.
20 Id., at section III.E.9.c.
21 17 CFR 270.2a–7(h)(10)(iii).
22 Another commenter stated that institutions and
intermediaries can demand more frequent
confirmations through independent negotiations
with money market fund providers. See Dreyfus
Letter, at 35. Such an option, however, would not
necessarily be available for retail investors in
institutional prime money market funds.
23 See 17 CFR 240.10b–10(b); see also supra, Note
4, citing certain specific relevant conditions.
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10(a), the broker-dealer must (1) notify
the customer of its ability to request
delivery of an immediate confirmation,
consistent with the written notification
requirements of Exchange Act Rule 10b–
10(a), and (2) not receive any such
request from the customer. This
condition would provide investors with
an option to receive confirmation
information regarding a transaction at or
before the completion of a securities
transaction, while also providing relief
to broker-dealers in circumstances
where customers would not view this
additional information as beneficial.
Taking all of these factors into
consideration, and consistent with the
exemptions and related conditions
applicable to money market funds that
attempt to maintain a stable NAV, the
Commission preliminarily believes that
a conditional exemption is necessary
and appropriate in the public interest,
and consistent with the protection of
investors. Therefore, the Commission
proposes to exempt broker-dealers from
the written notification requirements
under Exchange Act Rule 10b–10(a)
when effecting transactions in money
market funds operating in accordance
with Investment Company Act Rule 2a–
7(c)(1)(ii), for or with the account of a
customer, where: (i) No sales load is
deducted upon the purchase or
redemption of shares in the money
market fund, (ii) the broker-dealer
complies with the provisions of Rule
10b–10(b)(2) and Rule 10b–10(b)(3) that
are applicable to money market funds
that attempt to maintain a stable NAV
referenced in Rule 10b–10(b)(1),24 and
(iii) the broker-dealer has notified the
customer of its ability to request
delivery of an immediate confirmation
consistent with the written notification
requirements of Exchange Act Rule 10b–
10(a) and has not received such request
from the customer.
Solicitation of Comment
The Commission requests comment
on all aspects of this proposed
exemptive order, including, but not
limited to, the following questions:
• Do the monthly statements and
other requirements under Rule 10b–
10(b)(2) and (3) provide an appropriate
alternative to immediate confirmations
for transactions in floating NAV money
market funds? What are the advantages
and disadvantages to various market
participants (including broker-dealers,
24 The proposed conditions under ‘‘(i)’’ and ‘‘(ii)’’
above are consistent with the confirmation delivery
requirements provided in Exchange Act Rule 10b–
10(b) for all transactions in investment companies
that attempt to maintain a constant NAV where no
sales load or redemption fee is charged. 17 CFR
240.10b–10(b).
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shareholders, and funds) of permitting
broker-dealers to provide fund
shareholders of floating NAV money
market funds with monthly
confirmation statements?
• What are the reasons why
shareholders might prefer to receive
confirmation information immediately
for floating NAV money market funds?
What are the costs to broker-dealers
associated with providing immediate
confirmations? In particular, what are
the nature and magnitude of such costs
associated with providing immediate
confirmations, and what, if any, costs
would be passed along to investors?
• Should the Commission consider
any alternatives other than the proposed
exemption to the Exchange Act Rule
10b–10 requirements in the context of a
floating NAV fund outlined above, such
as requiring the provision of
confirmations to shareholders at some
different time interval (e.g., weekly
statements)? Should broker-dealers be
required to provide immediate
confirmations upon request by an
investor? Rather than requiring
immediate confirmations upon request
by an investor, should the Commission
consider any alternatives (e.g., requiring
next-day delivery upon investor
request)? What benefits and costs would
be associated with any alternative
approach?
• Should the Commission give
investors the option to request delivery
of an immediate confirmation statement
for floating NAV money market funds?
If investors should have that option,
should the Commission require that
broker-dealers notify the customer of its
ability to request delivery of an
immediate confirmation? What are the
advantages and disadvantages of
providing investors with the ability to
request immediate confirmations? What
are the potential effects on brokerdealers, investors, or other market
participants? Should the Commission
consider an alternative approach, such
as requiring immediate confirmations
unless the customer opts out?
• Would providing an exemption
from the immediate confirmation
delivery requirements of Exchange Act
Rule 10b–10, as proposed, provide
appropriate relief to broker-dealers and,
at the same time, provide sufficient
information to investors?
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–17748 Filed 7–28–14; 8:45 am]
BILLING CODE 8011–01–P
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Agencies
[Federal Register Volume 79, Number 145 (Tuesday, July 29, 2014)]
[Notices]
[Pages 44076-44078]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-17748]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-72658; File No. S7-08-14]
Notice of Proposed Exemptive Order Granting Permanent Exemptions
Under the Securities Exchange Act of 1934 From the Confirmation
Requirements of Exchange Act Rule 10b-10 for Certain Money Market Funds
July 23, 2014.
AGENCY: Securities and Exchange Commission.
ACTION: Notice of Proposed Exemptive Order; Request for Comment.
-----------------------------------------------------------------------
SUMMARY: Pursuant to Section 36 of the Securities Exchange Act of 1934
(``Exchange Act'') and Exchange Act Rule 10b-10(f), the Securities and
Exchange Commission (``SEC'' or ``Commission'') is proposing to grant
exemptive relief, subject to certain conditions, from the immediate
confirmation delivery requirements of Exchange Act Rule 10b-10 for
transactions effected in shares of any open-end management investment
company registered under the Investment Company Act of 1940
(``Investment Company Act'') that holds itself out as a money market
fund operating in accordance with Rule 2a-7(c)(1)(ii) of the Investment
Company Act.
DATES: Comments must be received on or before August 19, 2014.
ADDRESSES: Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/other.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number S7-08-14 on the subject line; or
Use the Federal Rulemaking Portal (https://www.regulations.gov). Follow the instructions for submitting comments.
Paper Comments
Send paper comments in triplicate to Kevin M. O'Neill,
Deputy Secretary, Securities and Exchange Commission, 100 F Street NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number S7-08-14. This file number
should be included on the subject line if email is used. To help us
process and review your comments more efficiently, please use only one
method. The Commission will post all comments on the Commission's
Internet Web site (https://www.sec/gov/rules/other.shtml). Comments are
also available for Web site viewing and printing in the Commission's
Public Reference Room, 100 F Street NE., Washington DC 20549, on
official business days between the hours of 10:00 a.m. and 3:00 p.m.
All comments received will be posted without charge; the Commission
does not edit personal identifying information from submissions. You
should only submit information that you wish to make publicly
available.
FOR FURTHER INFORMATION CONTACT: Natasha Vij Greiner, Branch Chief,
Jonathan C. Shapiro, Attorney-Adviser, George Makris, Attorney-Adviser,
at 202-551-5550, Division of Trading and Markets, Securities and
Exchange Commission, 100 F Street NE., Washington, DC 20549-7010.
I. Background
Exchange Act Rule 10b-10 addresses broker-dealers' obligations to
confirm their customers' securities transactions.\1\ Under Rule 10b-
10(a), a broker-dealer generally must provide customers with
information relating to their investment decisions at or before the
completion of a securities transaction.\2\ Rule 10b-10(b), however,
provides an exception for certain transactions in money market funds
that attempt to maintain a stable net asset value (``NAV'') and where
no sales load or redemption fee is charged.\3\ The exception permits
broker-dealers to provide transaction information to money market fund
shareholders on a monthly basis (subject to certain conditions set
forth in Rule 10b-10(b)(2) and (3)) in lieu of immediate confirmations
for all purchases and redemptions of shares of such funds.\4\
[[Page 44077]]
Accordingly, customers historically have received information for their
transactions in shares of money market funds on a monthly basis.
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\1\ 17 CFR 240.10b-10.
\2\ 17 CFR 240.10b-10(a).
\3\ 17 CFR 240.10b-10(b).
\4\ With respect to such money market funds, Exchange Act Rule
10b-10(b)(2) requires a broker-dealer to give or send to a customer
within five business days after the end of each monthly period a
written statement disclosing, each purchase or redemption, effected
for or with, and each dividend or distribution credited to or
reinvested for, the account of such customer during the month; the
date of such transaction; the identity, number, and price of any
securities purchased or redeemed by such customer in each such
transaction; the total number of shares of such securities in such
customer's account; any remuneration received or to be received by
the broker or dealer in connection therewith; and that any other
information required by Rule 10b-10(a) will be furnished upon
written request: Provided, however, that the written statement may
be delivered to some other person designated by the customer for
distribution to the customer. 17 CFR 240.10b-10(b)(2). Exchange Act
Rule 10b-10(b)(3) requires that such customer is provided with prior
notification in writing disclosing the intention to send the written
information referred to in Rule 10b-10(b)(1) in lieu of an immediate
confirmation. 17 CFR 240.10b-10(b)(3).
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Today, the Commission adopted amendments to Rule 2a-7 of the
Investment Company Act. Among other things, the amendments require
institutional prime money market funds, which, under the prior rule,
were permitted to maintain a stable net asset value, to sell and redeem
shares based on the current market-based value of the securities held
in their portfolios, i.e., transact at a ``floating'' NAV.\5\ As a
result, institutional prime money market funds, like other mutual
funds, will now be required to value their portfolio securities using
market-based factors (rather than amortized cost) and sell and redeem
shares at prices rounded to the fourth decimal place (rather than
rounded to the nearest penny).\6\ However, institutional prime money
market funds will continue to be subject to the ``risk limiting''
provisions of Rule 2a-7 and therefore will continue to be limited to
investing in short-term, high-quality, dollar-denominated
instruments.\7\
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\5\ See Money Market Fund Reform; Amendments to Form PF,
Securities Act Release No. 9616, Investment Advisers Act Release No.
3879, Investment Company Act Release No. 31166, at section III.B
(July 23, 2014) (``Money Market Fund Reform Adopting Release'').
\6\ Id.; Investment Company Act Rule 2a-7(c)(1)(ii), 17 CFR
270.2a-7(c)(1)(ii).
\7\ Money Market Fund Reform Adopting Release, at 143; see also
Investment Company Act Rule 2a-7(d), 17 CFR 270.2a-7(d) (risk-
limiting conditions).
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Given that share prices of such institutional prime money market
funds likely will fluctuate under the amended rule, absent exemptive
relief, broker-dealers will not be able to continue to rely on the
current exception under Rule 10b-10(b) for transactions in money market
funds operating in accordance with Rule 2a-7(c)(1)(ii).\8\ Instead,
broker-dealers will be required to provide immediate confirmations for
all such transactions.
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\8\ See generally Money Market Fund Reform; Amendments to Form
PF, Securities Act Release No. 9408, Investment Advisers Act Release
No. 3616, Investment Company Act Release No. 30551 (June 5, 2013),
78 FR 36834, 36934 (June 19, 2013); see also Exchange Act Rule 10b-
10(b)(1), 17 CFR 240.10b-10(b)(1) (limiting alternative monthly
reporting to money market funds that attempt to maintain a stable
net asset value).
As adopted, government and retail money market funds are exempt
from the Investment Company Act Rule 2a-7(c)(1)(ii) floating NAV
requirement, and therefore, will continue to maintain a stable NAV.
See Money Market Fund Reform Adopting Release, at sections III.C.1
and III.C.2. Accordingly, for investor transactions in such exempt
funds, broker-dealers would continue to qualify under the exception
under Rule 10b-10 and be permitted to send monthly transaction
reports.
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In the money market fund reform proposing release,\9\ the
Commission requested comment on whether, if the Commission adopted the
floating NAV requirement, broker-dealers should be required to provide
immediate confirmations to all institutional prime money market fund
investors. Commenters generally urged the Commission not to impose such
a requirement, arguing that there would be significant costs associated
with broker-dealers providing immediate confirmations.\10\ Such costs
are expected to include both (1) the ongoing costs of creating and
sending trade-by-trade confirmations and (2) the costs of implementing
new systems to generate confirmations.\11\ The Commission recognizes
that there may be costs associated with requiring immediate
confirmations for such transactions,\12\ and is aware that such costs
may be passed on to investors in funds subject to the floating NAV
requirements.\13\ Nonetheless, given that institutional prime money
market funds likely will fluctuate in price, some investors may find
value in receiving information relating to their investment decisions
at or before the completion of a securities transaction. The Commission
requests comments regarding these potential benefits.
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\9\ Money Market Fund Reform; Amendments to Form PF, 78 FR
36934.
\10\ See Letter from Paul Schott Stevens, President and CEO,
Investment Company Institute, to Elizabeth M. Murphy, Secretary,
Commission, dated September 17, 2013 (``Investment Company Institute
Letter''), at 37, available at https://www.sec.gov/comments/s7-03-13/s70313-200.pdf; Letter from Timothy W. Cameron, Managing Director,
SIFMA Asset Management Group, John Maurello, Managing Director,
SIFMA Private Client Group, Matthew J. Nevins, Managing Director and
Associate General Counsel, SIFMA Asset Management Group, dated Sept.
17, 2013 (``9/17/13 SIFMA Letter''), at Appendices 1 and 2,
available at https://www.sec.gov/comments/s7-03-13/s70313-199.pdf;
Letter from J. Charles Cardona, President, The Dreyfus Corporation,
to Elizabeth M. Murphy, Secretary, Commission, dated September 17,
2013 (``Dreyfus Letter''), at 35, available at https://www.sec.gov/comments/s7-03-13/s70313-167.pdf; Letter from John D. Hawke, Jr.,
Arnold & Porter, on behalf of Federated Investors, Inc. and its
subsidiaries, to Chair Mary Jo White, Commission, dated September
17, 2013 (``Federated Letter''), at 22, available at https://www.sec.gov/comments/s7-03-13/s70313-225.pdf; Letter from Anthony J.
Carfang, Partner, Cathryn R. Gregg, Partner, Paul LaRock, Principal,
Steven Wiley, Manager, Treasury Strategies, Inc., to Elizabeth M.
Murphy, Secretary, Commission, dated September 12, 2013 (``Treasury
Strategies Letter''), available at https://www.sec.gov/comments/s7-03-13/s70313-118.pdf.
\11\ See, e.g., Federated Letter, at 22.
\12\ Money Market Fund Reform Adopting Release, at section
III.B.7.
\13\ See, e.g., Dreyfus Letter, at 35 (``Confirming transactions
in [variable net asset value money market mutual funds] on a
transaction basis will increase costs, which will be passed on to
[money market mutual fund] investors or underwriters.'').
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II. Discussion of Proposed Relief
After careful consideration, the Commission is proposing to grant
exemptive relief pursuant to Section 36 of the Exchange Act \14\ and
Exchange Act Rule 10b-10(f) \15\ that would allow broker-dealers,
subject to certain conditions, to provide transaction information to
investors in any money market fund operating pursuant to Rule 2a-
7(c)(1)(ii) on a monthly basis in lieu of providing immediate
confirmations.
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\14\ Section 36 of the Exchange Act authorizes the Commission to
conditionally or unconditionally exempt any person, security, or
transaction, or any class or classes of persons, securities, or
transactions, from certain provisions of the Exchange Act or certain
rules or regulations thereunder, by rule, regulation, or order, to
the extent that such exemption is necessary or appropriate in the
public interest, and is consistent with the protection of investors.
15 U.S.C. 78mm.
\15\ Exchange Act Rule 10b-10(f) specifies the Commission may
conditionally or unconditionally exempt any broker or dealer from
the requirements of Rule 10b-10(a) and Rule 10b-10(b) with regard to
specific transactions or specific classes of transactions for which
the broker or dealer will provide alternative procedures to effect
the purposes of the rule. 17 CFR 240.10b-10(f).
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The floating NAV requirement, as adopted, only applies to
institutional prime money market funds--not to government or retail
money market funds.\16\ Shareholders that invest in institutional prime
money market funds will continue to have extensive investor protections
separate and apart from the protections provided under Exchange Act
Rule 10b-10. For example, as stated above, funds subject to the
floating NAV requirement will continue to be subject to the ``risk
limiting'' conditions of Rule 2a-7.\17\ These conditions limit the risk
in a money market fund's portfolio by governing the credit quality,
liquidity, diversification, and maturity of money market investments.
Accordingly, mutual funds that hold themselves out as money market
funds--including institutional prime money market funds--may acquire
only investments that are short-term, high-quality, dollar-denominated
instruments.\18\
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\16\ See Investment Company Act Rule 2a-7(c)(1)(ii), 17 CFR
270.2a-7(c)(1)(ii). As defined in Investment Company Act Rule 2a-
7(a)(25), as amended, a retail money market fund is defined as a
money market fund that has policies and procedures reasonably
designed to limit all beneficial owners of the fund to natural
persons. 17 CFR 270.2a-7(a)(25). Under Rule 2a-7(a)(16), a
government money market fund is defined as a money market fund that
invests 99.5 percent or more of its total assets in cash, government
securities, and/or repurchase agreements that are collateralized
fully. 17 CFR 270.2a-7(a)(16).
\17\ See Investment Company Act Rule 2a-7(d), 17 CFR 270.2a-7(d)
(risk-limiting conditions).
\18\ Id.; see also Money Market Fund Reform Adopting Release, at
143.
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[[Page 44078]]
While institutional prime money market fund shares will fluctuate,
they are not likely to fluctuate daily, primarily due to the high
quality and short duration of such funds' underlying portfolio
securities.\19\ In addition, the Commission anticipates that
information on prices will be available through other means.\20\ For
example, under the new fund disclosure requirements of Investment
Company Act Rule 2a-7(h)(10)(iii), investors--including institutional
investors--will be able to access a fund's daily mark-to-market NAV per
share on a money market fund's Web site.\21\ Moreover, as previously
noted, commenters raised concerns about the costs associated with
requiring immediate confirmation for such transactions, which, to some
extent, may be passed on to investors.\22\
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\19\ Id., at 155 n.491. Based on staff analysis of Form N-MFP
data between November 2010 and November 2013, 53% of money market
funds would have fluctuated in price over a twelve-month period with
an NAV priced using basis point rounding, compared with less than 5%
of money market funds that would have fluctuated in price using 10
basis point rounding. Id., at 158-59.
\20\ Id., at section III.E.9.c.
\21\ 17 CFR 270.2a-7(h)(10)(iii).
\22\ Another commenter stated that institutions and
intermediaries can demand more frequent confirmations through
independent negotiations with money market fund providers. See
Dreyfus Letter, at 35. Such an option, however, would not
necessarily be available for retail investors in institutional prime
money market funds.
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Under Exchange Act Rule 10b-10(b), the exemption from providing
immediate confirmations consistent with the written notification
requirements under Rule 10b-10(a) is subject to certain conditions.\23\
The Commission preliminarily believes that these conditions are also
appropriate for institutional prime money market funds subject to the
floating NAV requirement under Rule 2a-7(c)(1)(ii) in order to provide
customers with consistent information for all money market fund
transactions.
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\23\ See 17 CFR 240.10b-10(b); see also supra, Note 4, citing
certain specific relevant conditions.
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Given that there will be price fluctuations in institutional prime
money market funds, the Commission preliminarily believes that it may
be necessary or appropriate in the public interest and consistent with
the protection of investors to also require that broker-dealers provide
immediate confirmations upon a customer's request. Accordingly, to be
eligible for the exemption from Rule 10b-10(a), the Commission proposes
an additional condition beyond those in place pursuant to Rule 10b-
10(b). Specifically, the Commission proposes that, to be exempt from
the immediate confirmation requirements of Rule 10b-10(a), the broker-
dealer must (1) notify the customer of its ability to request delivery
of an immediate confirmation, consistent with the written notification
requirements of Exchange Act Rule 10b-10(a), and (2) not receive any
such request from the customer. This condition would provide investors
with an option to receive confirmation information regarding a
transaction at or before the completion of a securities transaction,
while also providing relief to broker-dealers in circumstances where
customers would not view this additional information as beneficial.
Taking all of these factors into consideration, and consistent with
the exemptions and related conditions applicable to money market funds
that attempt to maintain a stable NAV, the Commission preliminarily
believes that a conditional exemption is necessary and appropriate in
the public interest, and consistent with the protection of investors.
Therefore, the Commission proposes to exempt broker-dealers from the
written notification requirements under Exchange Act Rule 10b-10(a)
when effecting transactions in money market funds operating in
accordance with Investment Company Act Rule 2a-7(c)(1)(ii), for or with
the account of a customer, where: (i) No sales load is deducted upon
the purchase or redemption of shares in the money market fund, (ii) the
broker-dealer complies with the provisions of Rule 10b-10(b)(2) and
Rule 10b-10(b)(3) that are applicable to money market funds that
attempt to maintain a stable NAV referenced in Rule 10b-10(b)(1),\24\
and (iii) the broker-dealer has notified the customer of its ability to
request delivery of an immediate confirmation consistent with the
written notification requirements of Exchange Act Rule 10b-10(a) and
has not received such request from the customer.
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\24\ The proposed conditions under ``(i)'' and ``(ii)'' above
are consistent with the confirmation delivery requirements provided
in Exchange Act Rule 10b-10(b) for all transactions in investment
companies that attempt to maintain a constant NAV where no sales
load or redemption fee is charged. 17 CFR 240.10b-10(b).
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Solicitation of Comment
The Commission requests comment on all aspects of this proposed
exemptive order, including, but not limited to, the following
questions:
Do the monthly statements and other requirements under
Rule 10b-10(b)(2) and (3) provide an appropriate alternative to
immediate confirmations for transactions in floating NAV money market
funds? What are the advantages and disadvantages to various market
participants (including broker-dealers, shareholders, and funds) of
permitting broker-dealers to provide fund shareholders of floating NAV
money market funds with monthly confirmation statements?
What are the reasons why shareholders might prefer to
receive confirmation information immediately for floating NAV money
market funds? What are the costs to broker-dealers associated with
providing immediate confirmations? In particular, what are the nature
and magnitude of such costs associated with providing immediate
confirmations, and what, if any, costs would be passed along to
investors?
Should the Commission consider any alternatives other than
the proposed exemption to the Exchange Act Rule 10b-10 requirements in
the context of a floating NAV fund outlined above, such as requiring
the provision of confirmations to shareholders at some different time
interval (e.g., weekly statements)? Should broker-dealers be required
to provide immediate confirmations upon request by an investor? Rather
than requiring immediate confirmations upon request by an investor,
should the Commission consider any alternatives (e.g., requiring next-
day delivery upon investor request)? What benefits and costs would be
associated with any alternative approach?
Should the Commission give investors the option to request
delivery of an immediate confirmation statement for floating NAV money
market funds? If investors should have that option, should the
Commission require that broker-dealers notify the customer of its
ability to request delivery of an immediate confirmation? What are the
advantages and disadvantages of providing investors with the ability to
request immediate confirmations? What are the potential effects on
broker-dealers, investors, or other market participants? Should the
Commission consider an alternative approach, such as requiring
immediate confirmations unless the customer opts out?
Would providing an exemption from the immediate
confirmation delivery requirements of Exchange Act Rule 10b-10, as
proposed, provide appropriate relief to broker-dealers and, at the same
time, provide sufficient information to investors?
By the Commission.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-17748 Filed 7-28-14; 8:45 am]
BILLING CODE 8011-01-P