Money Market Funds


Our Premier Practice
Stradley Ronon offers one of the premier practices in the nation relating to money market funds under the Investment Company Act of 1940. Money market fund regulation is not an area for dabblers – and we have taken a deep dive. The breadth of our experience in money market fund regulation allows us to tackle cutting-edge issues with technical knowledge and practical savvy. In an ever-changing regulatory landscape, we remain at the forefront of money market fund developments and are positioned to advise our clients on matters that may impact the operation of money market funds.

Our Experienced Attorneys
The Stradley Ronon team is highly respected for its ability to explain clearly the industry’s complicated regulations and assist compliance personnel and fund boards with meeting their legal obligations while carrying out their corporate responsibilities. Our experienced money market fund practitioners work collaboratively with lawyers throughout the firm to address the many and varied issues impacting money market fund management, operations and compliance, including ISDA documentation, bankruptcy concerns, tax issues and banking-related matters.

Retired Counsel Joan Ohlbaum Swirsky, one of the foremost practitioners and thought leaders in legal issues concerning money market funds, is the author of “The Guide to Rule 2a-7: A Map Through the Maze for the Money Market Professional,” the definitive resource on the subject area and a book so well respected that even regulators have ordered copies.

Our Comprehensive Services
We help clients with all aspects of money market fund management and regulatory compliance, including:

  • Interpreting and complying with Securities and Exchange Commission (SEC) rules and related requirements governing all types of money market funds, including prime, retail, tax-exempt and government money market funds.
  • Advising clients on requirements related to liquidity fees and redemption gates, including advising independent directors/trustees with respect to their responsibilities and fiduciary duties related to liquidity fees and redemption gates.
  • Reviewing securities for eligibility as money market fund investments under Rule 2a-7.
  • Advising on Form N-CR filing obligations.
  • Addressing troubled holdings in money market portfolios, including related communications with the fund board, the public and SEC staff (such as seeking no-action relief).
  • Obtaining relief from SEC regulatory requirements.
  • Seeking advice from regulators regarding money market fund regulation questions.
  • Developing and reviewing money market fund compliance policies and procedures.
  • Responding to SEC examinations and inquiries relating to money market funds.
  • Advising on SEC enforcement proceedings involving money market funds.
  • Conducting training sessions for portfolio personnel, board members, compliance officers, and others relating to money market fund management and compliance.
  • Handling day-to-day portfolio compliance issues for money market funds.
  • Interpreting U.S. Treasury Department and Internal Revenue Service guidance regarding tax compliance issues and tax implications for money market funds.


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