Invesco Primer on Form N-CR
Invesco recently posted two separate Money Market Reform Regulatory Updates. The first is "Implementation Time for Significant Event Reporting (Form N-CR)," while the other is "Reform Update: SEC Implementation Schedule." On Form N-CR, Invesco says, "As part of the new amendments to Rule 2a-7, which governs money market funds, approved in July 2014, the Securities and Exchange Commission (SEC) introduced new requirements for money market funds to report certain significant events on Form N-CR. The intent of this new form is to help the SEC enhance oversight of money market funds and provide important transparency to fund shareholders. The compliance data for Form N-CR and corresponding website disclosure is July 14, 2015. When certain specific events occur, money market funds are required to file a disclosure report to the SEC with certain information about the event. The initial report to the SEC needs to be submitted within one business day and an amended report needs to be submitted within four business days to include a brief description of the actions taken in response to the events." It also lists the events that would require disclosure: defaults and events of insolvency, financial support by sponsors or affiliates, declines in shadow price, imposition and filing of liquidity fee and redemption gates. The SEC implementation Schedule, includes a list of all the dates for the implementation of reforms, starting with Form N-CR in July 2015. In other news, SimCorp, a provider of investment management solutions, will host a one-hour webinar on Wednesday July 15 on "Money Market Reform: The implications for your firm and the available technology solutions to help you comply." Law-firm Dechert described Form N-CR <b:>`_ in their May 2015 update, "U.S. Money Market Fund Reform: Form N-CR and Related Website Disclosure Compliance Deadline Quickly Approaching." They said, "On July 23, 2014, the SEC approved sweeping amendments to Rule 2a-7 and other rules that govern money market funds under the Investment Company Act of 1940. Among other requirements, the SEC adopted new Rule 30b1-8 under the 1940 Act, which will require a money market fund to report information to the SEC regarding certain material events on Form N-CR. Under this new reporting requirement, a money market fund must provide a brief summary of a Material Event within one business day of the occurrence of that Material Event and, for certain Material Events, the fund also must provide a follow-up report that includes more complete information within four business days. Any filings made on Form N-CR will become immediately public on the SEC's EDGAR website. Money market funds will be required to file Form N-CR with the SEC for any Material Events occurring on or after July 14, 2015."
