A Commission proposal from July 2009 would require the filing of new Form N-MFP by money market funds to report detailed information about their portfolio holdings. This information would be filed in a format that would permit the Commission to create a searchable database of money market fund information. The new form would require more detailed information than required by the Treasury Department’s Temporary Guarantee Program for Money Market Funds ("Guarantee Program"). The Guarantee Program has guaranteed the $1 share value of accounts and was designed to help stabilize money market funds following the substantial redemptions that were threatening the maintenance of the $1 share value. This program was in effect for a year before its September 18, 2009 expiration.

Upon expiration of the Guarantee Program, the Commission enacted an interim final temporary rule. This rule was designed to continue with the disclosure requirements of the Guarantee Program. It does not require the use of a new form, instead requiring notification to the Commission by electronic mail. The money market firms will provide to the Commission to same Microsoft Excel files that were used in the Guarantee Program reporting.

The Commission noted that before the fall of 2008, only one money market fund had ever "broken the buck," where it closed at less than $1 per share. Recent losses in the subprime market have, however, placed a great deal of pressure on these funds, and money market funds faced losses in the falling commercial paper markets. The bankruptcy of Lehman Brothers added to the difficulties. The July proposal was designed to address credit risk at money market funds, and the interim final temporary rule was designed to continue disclosure required by the Guarantee Program.

Under the July proposal, Form N-MFP, monthly schedule of portfolio holdings of money market funds, would require detailed information on holdings, advisers and sub-advisers, liquidity providers and independent auditors, among other things.

The Investment Company Institute ("ICI"), in comments on the July proposal, wrote that it worries about some of the information on Form N-MFP. Investors might misinterpret a decline in the amortized cost net asset value as an indication of problems with the fund, according to the ICI. The ICI noted that Item 13 of Form N-MFP would require reporting of net value of other assets and liabilities to the nearest hundredth of a cent. Item 37 would require the current amortized cost of each security to the nearest hundredth of a cent. According to the ICI, the accounting systems of funds do not maintain information to the nearest hundredth of a cent, but instead only to the nearest cent. ICI recommends changing the proposal to the nearest cent.

T. Rowe Price argued against public disclosure of the information proposed for Form N-MFP. The proposal calls for public release two weeks after the filing is made. T. Rowe Price is also opposed to certification requirements for the form, which it believes would be extremely onerous. Dreyfus noted that under the proposal’s monthly Form N-MFP requirement, it would have to make 612 more annual filings.