On January 27, 2010, the US Securities and Exchange Commission (SEC), by a 4-1 vote, adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the “1940 Act”).1 Rule 2a-7 (the “Rule”) imposes quality, liquidity, and other requirements on any registered investment company that holds itself out to the public as a “money market fund.” Compliance with the amended Rule will be phased in over time as described further below.