We learned from Stradley Ronon's Joan Ohlbaum Swirsky that the SEC has revised its "Staff Responses to Questions about Rule 30b1-7 and Form N-MFP to clarify holdings disclosure dates on Form N-MFP and a couple other points. The updated Q&A says, "Q: Rule 30b1-7 requires that the report of portfolio holdings on Form N-MFP be current as of the last business day of the previous month. Some funds have indicated that they compile the portfolio holdings information as of the last calendar day of the month, even if that day is on a Saturday, Sunday or holiday. In these circumstances, may the fund's report of portfolio holdings on Form N-MFP be current as of a calendar day in the month after the last business day of the month? A: Commission staff would not object if a fund reports the portfolio holdings information on Form N-MFP current as of a day in the month on or after the last business day of the month.... Item 36 -- Final legal maturity date. Should the security's final legal maturity date be the same as the date used to calculate the fund's WAL? A: Yes. See also footnote 154 of the Adopting Release."
