The Securities & Exchange Commission recently posted a document entitled, "EDGAR Form N-MFP XML Technical Specification (Version 1), which had an "Implementation Date" of August 30, 2010. While we don't claim to understand most of this document (like most things in the SEC's EDGAR database, only a computer programmer can understand it), it was one of the final pieces that fund companies were awaiting before implementing one of the final pieces of the SEC's Money Market Fund Reform, the disclosure of portfolio information.
The original SEC MMF Reforms (see page 72) said, "We are amending rule 2a-7 to require money market funds to disclose information about their portfolio holdings each month on their websites. The disclosure will provide greater transparency of portfolio information in a manner convenient for most investors. The amendment is designed to give investors a better understanding of the current risks to which the fund is exposed, strengthening their ability to exert influence on risk-taking by fund advisers.... As proposed, the amendments to rule 2a-7 would have required a fund to disclose the fund's schedule of investments."
The Rule 2a-7 Reforms explain, "We are adopting a new rule requiring money market funds to provide the Commission a monthly electronic filing of more detailed portfolio holdings information. The information will permit us to create a central database of money market fund portfolio holdings, which will enhance our oversight of money market funds and our ability to respond to market events. As discussed further below, the information will also be made public on a delayed basis. New rule 30b1-7 requires money market funds to report portfolio information on new Form N-MFP."
It continues, "Money market funds must report on Form N-MFP, with respect to each portfolio security held on the last business day of the prior month, the following items: (i) the name of the issuer; (ii) the title of the issue, including the coupon or yield; (iii) the CUSIP number; (iv) the category of investment (e.g., Treasury debt, government agency debt, asset backed commercial paper, structured investment vehicle note, repurchase agreement); ... (ix) the principal amount; (x) the current amortized cost value; (xi) the percentage of the money market fund’s assets invested in the security; (xii) whether the security is an illiquid security (as defined in amended rule 2a-7(a)(19)); and (xiii) 'Explanatory notes.'"
The SEC says, "Form N-MFP also requires funds to report to us information about the fund, including information about the fund's risk characteristics such as the dollar weighted average maturity of the fund's portfolio and its seven-day gross yield. Money market funds also must report on Form N-MFP the market-based values of each portfolio security and the fund's market-based net asset value per share, with separate entries for values that do and do not take into account any capital support agreements into which the fund may have entered. Under rule 30b1-7, the information contained in the portfolio reports that money market funds file with the Commission on Form N-MFP will be available to the public 60 days after the end of the month to which the information pertains."
They added, "In response to commenters, we are delaying the mandatory filing date for several months after the effective date of the amendments, to permit money market funds to develop systems necessary to collect and submit the portfolio information on Form N-MFP. Thus, the first mandatory filing will be due on December 7, 2010, for holdings as of the end of November 2010. For approximately two months before the first mandatory filing, our staff will accept the submission of trial data so that money market funds may voluntarily make (non-public) electronic submissions with us." (These filings will be available to the public starting 60 days later, around Feb. 7, 2011.)
The new EDGAR Form N-MFP posting says, "In support of the adoption of new rule 30b1-7 under the Investment Company Act of 1940 and new Form N-MFP, which were included in the Commission's recent money market fund reform package (See Release No. IC-29132 [75 FR 10060]), the EDGAR system was upgraded to Release 10.3 on August 30, 2010. EDGAR Release 10.3 will deploy new submission types N-MFP and N-MFP/A to facilitate the electronic filing of the new form. Filers must follow the Form N-MFP XML Technical Specification to construct their Form N-MFP and Form N-MFP/A submissions via the EDGAR Filing Web site (https://edgarfiling.sec.gov) or by clicking the 'Are you an EDGARLink filer or would you like to create a new Asset-Backed Securities Issuing Entity?' link from the EDGAR Portal Web site (www.portal.edgarfiling.sec.gov).
It adds, "The following EDGAR Form N-MFP XML Technical Specification documents detail the valid structure and content of the EDGAR Form N-MFP submission types (N-MFP and N-MFP/A)." This page offers a link to: "Download the EDGAR Form N-MFP XML Technical Specification (Version 1) (compressed folder)."
