SECTION 1. PURPOSE

This notice relates to the Temporary Guarantee Program for Money Market Funds (the “Program”), which is provided by the Treasury Department in response to the credit market instability to make available certain funds from its Exchange Stabilization Fund, upon prescribed terms and conditions, to money market funds that are regulated under the Security and Exchange Commission’s Rule 2a–7, 17 C.F.R. 270.2a–7, under

the Investment Company Act of 1940 (“Rule 2a–7”). Some practitioners have expressed concern that participation in the Program may raise certain potential tax issues for money market funds whose beneficial interests are held exclusively by one or more segregated asset accounts of one or more insurance companies (or other investors permitted under § 1.817–5(f)(3) of the Income Tax Regulations) (“Insurance-Dedicated Money Market Funds”). This notice provides certainty with respect to those issues, as described below.