Washington, D.C., Sept. 17, 2008 — The Securities and Exchange Commission’s Office of the Chief Accountant clarified that bank support of money market mutual funds generally does not result in a requirement to present the fund on-balance sheet. As a result of recent market events, it is possible that some money market funds could become exposed to declines in the credit worthiness of troubled assets. To protect investors’ principal investment in these funds, sponsoring financial institutions can provide various types of financial support.
The Office of the Chief Accountant has received questions related to whether the actions by these sponsoring financial institutions may result in on-balance sheet accounting for supported money market funds. The Office of the Chief Accountant believes that on-balance sheet accounting for supported money market funds is not required if the sponsoring financial institution does not absorb the majority of the expected future risk associated with the money market fund’s assets, including interest rate, liquidity, credit and other relevant risks that are expected to impact the value of the money market fund assets. However, SEC staff would expect adequate disclosure of the nature of the support provided.