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What ERISA Service Providers Should Know About Money Market Reform (PDF)
Drinker Biddle Link to more items from this source
Oct. 30, 2014
"[D]efined benefit plans, endowments and small businesses are not considered 'natural persons' and would not be eligible to invest in a retail money market fund.... The SEC provided examples of how funds could satisfy the natural person definition with intermediaries ... ERISA service providers who hold fund shares in omnibus accounts may expect to be contacted by retail money market funds to provide these certifications or representations and/or to enter into new agreements with funds for this purpose.... The liquidity fee and gate requirements will usually only be triggered in times of extreme market stress. But they are features that many ERISA participants and ERISA service providers will not find appealing."

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