Supporting Statement N-MFP

OMB CONTROL NUMBER: 3235-0657

SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection Submission for
Rule 30b1-7 and Form N-MFP
A.

JUSTIFICATION
1.

Necessity for the Information Collection

Section 30(b) of the Investment Company Act of 1940 (“Investment Company
Act”) 1 provides that “[e]very registered investment company shall file with the
Commission … such information, documents, and reports (other than financial
statements), as the Commission may require to keep reasonably current the information
and documents contained in the registration statement of such company….” 2
Rule 30b1-7 under the Investment Company Act, entitled “Monthly Report for
Money Market Funds,” provides that every registered investment company, or series
thereof, that is regulated as a money market funds under rule 2a-7 3 must file with the
Commission a monthly report of portfolio holdings on Form N-MFP 4 no later than the
fifth business day of each month. 5 Form N-MFP sets forth the specific disclosure items
that money market funds must provide. Filers must submit this report electronically using
the Commission’s electronic filing system (“EDGAR”) in Extensible Markup Language
(“XML”) format.

1

15 U.S.C. 80a-1 et seq.

2

15 U.S.C. 80a-30(b).

3

17 CFR 270.2a-7.

4

17 CFR 274.201.

5

17 CFR 270.30b1-7.

Compliance with rule 30b1-7 is mandatory for any fund that holds itself out as a
money market fund in reliance on rule 2a-7. Responses to the disclosure requirements
will not be kept confidential. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a currently valid
OMB control number.
On July 12, 2023, the Securities and Exchange Commission adopted amendments
to Form N-MFP’s reporting requirements. 6 As discussed more fully in the adopting
release, the amended reporting requirements: (1) increase the frequency of certain data
points from weekly to daily; (2) collect new information about securities that have been
disposed of before maturity; (3) collect new information about the composition and
concentration of money market funds’ shareholders; (4) collect new information about
the use of liquidity fees and share cancellation; and (5) collect additional information
about repurchase agreement transactions, as well as certain other information about the
fund’s portfolio securities. The amendments also improve identifying information about
the fund, including changes to better identify different categories of government money
market funds, changes to identify privately offered funds that are used for internal cash
management purposes, and amendments to provide the name and other identifying
information for the registrant, series, and class.

6

See Money Market Fund Reforms; Form PF Reporting Requirements for Large Liquidity Fund
Advisers; Technical Amendments to Form N-CSR and Form N-1A, Investment Company Act
Release No. 34959 (Jul. 12, 2023) [88 FR 51404 (Aug. 3, 2023)] (“2023 MMF Reforms”).

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2.

Purpose and Use of the Information Collection

Certain of the provisions of the rule, including the amendments, contain
“collection of information” requirements within the meaning on the Paperwork Reduction
Act of 1995 (“Paperwork Reduction Act”), 7 and the Commission is submitting the
collection of information to the Office of Management and Budget (“OMB”) for review.
The information collection requirements of rule 30b1-7 and reports on Form N-MFP are
designed to assist the Commission in analyzing the portfolio holdings of money market
funds, and thereby augment our understanding of the risk characteristics of individual
money market funds and money market funds as a group and industry trends. This
information collection enhances our oversight of money market funds and our ability to
respond to market events. In addition, although the portfolio reports to the Commission
are not primarily designed for individual investors, the information will be available to
the public. Academic researchers, financial analysts, and economic research firms may
use the information to study money market fund holdings and evaluate their risk
information, and their analyses may further help investors and regulators better
understand risks in money market funds.
3.

Consideration Given to Information Technology

The Commission’s Electronic Data Gathering, Analysis, and Retrieval System
(“EDGAR”) automates the filing, processing, and dissemination of full disclosure filings.
This automation has increased the speed, accuracy, and availability of information,

7

44 U.S.C. 3501 et seq.

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generating benefits to investors and financial markets. Funds are required to file reports
on Form N-MFP on EDGAR. 8 In addition, the XML-tagged format facilitates efficient
and expeditious analysis of portfolio holdings information by the Commission and other
interested persons.
4.

Duplication

The Commission periodically evaluates rule-based reporting and recordkeeping
requirements for duplication and reevaluates them whenever it proposes a rule or form or
a change in a rule or form. The information provided under rule 30b1-7 and reports on
Form N-MFP may duplicate some information included in other filings with the
Commission and/or information required to be disclosed on fund websites. Unlike other
filings, however, reports of Form N-MFP must be filed in XML-tagged format, which
facilitates staff analysis of portfolio holdings information and enhances Commission
oversight of money market funds.
5.

Effect on Small Entities

The information collection requirements of Form N-MFP do not distinguish
between small entities and other funds. The burden of the conditions on smaller funds
may be proportionally greater than for larger funds. This burden includes the cost of
producing and filing the reports. The Commission believes, however, that imposing
different requirements on smaller money market funds would not be consistent with
investor protection. The Commission reviews all rules periodically, as required by the

8

See rule 101(a)(1)(iv) of Regulation S-T [17 CFR 232.101(a)(1)(iv)].

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Regulatory Flexibility Act, to identify methods to minimize recordkeeping or reporting
requirements affecting small businesses.
With respect to the final amendments, pursuant to 5 U.S.C. section 605(b), the
Commission certified that the amendments to Form N-MFP will not have a significant
impact on a substantial number of small entities.
6.

Consequences of Not Conducting Collection

Rule 30b1-7 provides that money market funds file a report on Form N-MFP each
month. Given the rapidly changing composition of money market fund portfolios, which
consist of only short-term securities, we believe that less frequent collections would
render the portfolio information less timely and relevant.
7.

Inconsistencies With Guidelines in 5 CFR 1320.5(d)(2)

This collection is not inconsistent with 5 CFR 1320.5(d)(2).
8.

Consultation Outside the Agency

On December 15, 2021, the Commission issued a proposing release soliciting
comment on collections of information related to, among other things, the proposed
amendments to Form N-MFP. 9 The Commission’s solicitation of public comments
included estimating and requesting public comments on updated burden estimates for all
information collections under this OMB control number (i.e., both changes associated
with the rulemaking and other burden updates). Comments on the Commission’s releases

9

See Money Market Fund Reforms, Investment Company Act Release No. 34441 (Dec. 15, 2021)
[87 FR 7248 (Feb. 8, 2022)] (the “Proposing Release”).

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are generally received from registrants, investors, and other market participants. In
addition, the Commission and staff participate in an ongoing dialogue with
representatives of various market participants through public conferences, meetings, and
informal exchanges. All comments received on the proposal are available at
https://www.sec.gov/comments/s7-22-21/s72221.htm. The Commission considered all
comments received prior to publishing the final rules as required by 5 CFR 1320.11(f).
The Commission did not receive public comment regarding the PRA estimates for Form
N-MFP in the Proposing Release.
9.

Payment or Gift

No payment or gift to respondents was provided.
10.

Confidentiality

Information received pursuant to this collection of information will be kept
private to the extent permitted by law.
11.

Sensitive Questions

Form N-MFP collects information that is relevant to an evaluation of the risk
characteristics of the fund and its portfolio holdings. No information of a sensitive
nature, including social security numbers, is required under this collection of information.
The information collection does collect basic personally identifiable information (PII)
that may include name and job title. However, the agency has determined that the
information collection does not constitute a system of record for purposes of the Privacy
Act. In accordance with Section 208 of the E-Government Act of 2002, the agency has
conducted a Privacy Impact Assessment (PIA) of the EDGAR system, in connection with
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this collection of information. The EDGAR PIA, published on March 22, 2023, is
provided as a supplemental document and is also available at
https://www.sec.gov/privacy.
12.

Burden of Information Collection

The following estimates of average burden hours and costs are made solely for
purposes of the Paperwork Reduction Act and are not derived from a comprehensive or
even representative survey or study of the cost of Commission rules and forms. A fund
must comply with the requirement to prepare Form N-MFP in order to hold itself out to
investors as a money market fund or the equivalent of a money market fund in reliance on
rule 2a-7. The collection of information is mandatory for money market funds that rely
on rule 2a-7, and responses to the information collections will not be kept confidential.
We are revising our total burden estimates to reflect the adopted amendments to
Form N-MFP, as discussed above. 10 The respondents to these collections of information
will be money market funds. The Commission estimates there are 294 money market
funds that report information on Form N-MFP although certain components of the new
collections of information will apply to certain subsets of money market funds, as
reflected in the below table.
We estimate that 35% of money market funds (or 103 money market funds)
license a software solution and file reports on Form N-MFP in house. We estimate that
the remaining 65% of money market funds (or 191 money market funds) retain the

10

See 2023 MMF Reforms supra note 6. For the previously approved estimates, see ICR Reference
No. 202203-3235-024.

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services of a third party to provide data aggregation and validation services as part of the
preparation and filing of reports on Form N-MFP on the fund’s behalf. We understand
that the required data in the final amendments to Form N-MFP generally are already
maintained by money market funds pursuant to other regulatory requirements or in the
ordinary course of business. Accordingly, for the purposes of our analysis, we do not
believe that the final amendments add significant burden hours for filers of Form N-MFP.
In our most recent PRA submission for Form N-MFP, we estimated the annual
aggregate compliance burden to comply with the collection of information requirement of
Form N-MFP is 44,263 burden hours with an internal cost burden of $14,385,475 and an
external cost burden estimate of $2,613,300. 11 The table below summarizes our PRA
initial and ongoing annual burden estimates associated with the amendments to Form NMFP.

11

This estimate is based on the last time the PRA submission for the rule’s information collection
was approved in 2022 (OMB Control No. 3235-0657).

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Table 1: Burden Estimate for Form N-MFP
Internal initial

Internal annual

burden hours

burden hours

Wage rate

2

PROPOSED ESTIMATES
Reporting on disposed securities

3 hours

Number of funds for disposed securities
information
Total new annual burden for disposed
securities information (I)
Other proposed amendments

9 hours

2 hours

3

Internal time

Annual external

costs

cost burden

1

×

$304

$608

× 64

x 64

128 hours

$38,912
$2,128

$912

× 318

x 318

x 318

2,226 hours

$676,704

$290,016

Total new annual burden (I +II)

2,354 hours

$715,616

$290,016

Current burden estimates

64,667 hours

$6,754,832

$3,179,700

Revised burden estimates

67,021 hours

$7,470,448

$3,469,716

Number of funds
Total new annual burden for Other
proposed amendments (II)

7 hours

$304

FINAL ESTIMATES
Reporting on disposed securities

3 hours

Number of funds for disposed securities
information6
Total new annual burden for disposed
securities information (I)
Other proposed amendments

×

$3465

$692

× 60

x 60

120 hours

$41,520
$1,903

$912

× 294

x 294

x 294

1,617 hours

$559,482

$268,1289

Total new annual burden (I +II)

1,737 hours

$601,002

$268,128

Current burden estimates

44,263 hours

$6,319,950

$2,613,300

Revised burden estimates

46,000 hours

$6,920,952

$2,881,428

Number of funds8
Total new annual burden for Other
proposed amendments (II)

7.5 hours

2 hours4

5.5 hours7

$3465

Notes:
1. For additional detail about the proposed estimates, see Proposing Release, supra note 9, at section IV.B.
2. This estimate includes the initial burden estimates amortized over a three-year period.
3. The Commission’s estimates of the relevant wage rates are based on salary information for the securities industry compiled by the Securities Industry and Financial
Markets Association’s Office Salaries in the Securities Industry 2013. The estimated wage figures are modified by Commission staff to account for an 1,800-hour
work-year and multiplied by 5.35 to account for bonuses, firm size, employee benefits, overhead, and adjusted to account for the effects of inflation. These PRA
estimates assume that the same types of professionals would be involved in the new reporting requirements that we believe otherwise would be involved in preparing

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and filing reports on Form N-MFP.
4. This estimate assumes that, after the initial 3 hours that a fund would spend complying with the requirement to report on disposed securities, which we annualized
over a 3-year period, the fund would incur 1 additional burden hour associated with ongoing compliance with this reporting requirement.
5. This represents a blended hourly rate of $347 for a Financial Reporting Manager ($339 per hour), Fund Senior Accountant ($252 per hour), Senior Database
Administrator ($397 per hour), Senior Portfolio Manager ($383 per hour), and Compliance Manager ($360 per hour)). The blended hourly rate was calculated as
($339 + $252 + $397 + $383 + $360) / 5 = $346 rounded to the nearest whole dollar.
6. This reflects that our final amendments require that only prime money market funds report information about disposed securities on Form N-MFP. We estimate
that there were 60 prime funds as of Mar. 2023, based on Form N-MFP filings.
7. This estimate assumes that, after the initial 7.5 hours that a fund would spend complying with the other amendments to Form N-MFP, which we annualized over a
3-year period, the fund would incur 3 additional burden hours associated with ongoing compliance with the reporting requirements.
8. We estimate that there were 294 money market funds as of Mar. 2023, based on Form N-MFP filings.
9. This estimate is based on the following information and calculations: (35% x $4,805 (the average cost to license a third-party software solution per year) =
$1,681.75) + (65% x $11,440 (the average cost of retaining the services of a third-party vendor to prepare and file reports on Form N-MFP on the fund’s behalf) =
$7,436) = basis for existing external N-MFP filing costs. We estimate that the new Form N-MFP requirements will add an additional 10% costs (e.g., ($1,681.75 +
$7,436 = $9,117.75) x 10% = $912 per fund). $912 x 294 = $268,128.

TABLE 2: CHANGE IN BURDEN ESTIMATES FOR FORM N-MFP
Annual Number of Responses
Previously

Revised

Approved

Estimate

4,236

4,236

13.

Annual Time Burden (hours)
Previously

Revised

Change

Approved

Estimate

0

44,263

46,000

Cost Burden (dollars)
Previously

Revised

Change

Approved

Estimate

Change

1,737

$2,613,300

$2,881,428

$268,128

Cost to Respondents

Cost burden is the cost of goods and services purchased to comply with rule 30b17 and Form N-MFP, such as licensing software solutions or for the services of external

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service providers. As discussed in Tables 1 and 2 above, the total estimated external cost
associated with this information collection has increased from $2,613,300 to $2,881,428
as a result of the amendments.
14.

Costs to Federal Government

The annual cost of reviewing and processing disclosure documents, including new
registration statements, post-effective amendments, proxy statements, shareholder
reports, and other filings of investment companies amounted to approximately $29
million in fiscal year 2022, based on the Commission’s computation of the value of staff
time devoted to this activity and related overhead.
15.

Changes in Burden

The total annual hour burden of 46,000 hours represents an increase of 1,737
hours over the previous burden estimate of 44,263 hours. The total annual external cost
burden of $2,881,428 represents an increase of $268,128 over the prior burden estimate
of $2,613,300.
The change in burden hours and external costs is due to the increased burdens
associated with the recent amendments.
16.

Information Collection Planned for Statistical Purposes

The results of any information collected will not be published.
17.

Approval to Omit OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of
the form. Including the expiration date on the electronic version of the form will result in

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increased costs, because the need to make changes to the form may not follow the
application’s scheduled version release dates. The OMB control number will be
displayed.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions

The Commission is not seeking an exception to the certification statement.
B.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL
METHODS
The collection of information will not employ statistical methods.

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