​ Money Funds Should Continue Annualizing With 365 Days in Leap Year. After being asked, we consulted the SEC about whether annualizing with 366 days during the current leap year is okay. The Commission said no, directing us to an old letter from Gene Gohlke, which states, "We have been informed that a number of money market funds, including the registrant, have recently been advertising and publishing annualized 7-​day yield quotations based on a multiplier of 366/​7 rather than the 365/​7 multiplier specified by applicable commission rules. Apparently, those using the 366 multiplier are doing so because 1984 is a leap year with 366 days. Computations for advertised yields of money market mutual funds were standardized by pertinent provisions of Forms N-​1 and N-​1A and Rule 482. Rule 483 does not provide for the use of 366 days in leap years.... If the Registrant is using a 366 day multiplier, please switch back to 365 as soon as possible." The SEC 7-​Day Yield Formula, the standard measure of performance for money funds, is the sum of 7 days' dividends, multiplied by 365/​7*​100.

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