Sponsors of money market fund busy implementing the current round of money market reforms may be overlooking some of the reporting issues the changes raise. Confluence addresses those issues in a white paper released in the Resource Center on its Web site this week.
The Pittsburgh-based firm warns fund complexes that manually complying with the new rules could prove costly, pointing out that the SEC estimates that the filing “would impose 152 burden hours at a cost of $42,712 per money market fund for the first year, and 120 burden hours at a cost of $33,720 per money market fund in subsequent years.”
“When tackled manually, it is a daunting task, requiring countless hours for data collection, report creation, content confirmation, and report delivery," says Scott Powell, Product Manager at Confluence.
The white paper also includes a definition of the new Form N-MFP and the data involved; a “readiness checklist” and appendices detailing the public Web site and Form N-MFP content and data requirements as noted in the Money Market Mutual Fund Reform Rule.
The rules call for money funds to:
file pre-existing quarterly holdings reporting through a Schedule of Investments (SEC Form N-Q).
Provide monthly reporting of specific portfolio holdings information via the fund’s Web site;
Deliver designated fund-specific and portfolio holdings information to the SEC via the new eXtensible Markup Language (XML)-based Form N-MFP;
Complete both reporting functions within five business days of month end; and
Begin monthly Web site reporting on October 7, 2010 for the period ending September 30, 2010, as well as monthly XML Form N-MFP reporting on December 7, 2010 for the period ending November 30, 2010. A voluntary Form N-MFP period begins October 7, 2010.
Sean Hanna, Editor in Chief
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