On March 19, 2020, the SEC staff (Staff) issued a no-action letter to the Investment Company Institute (ICI Letter) that provides relief to money market funds (MMFs). In the ICI Letter, the Staff will permit an affiliated person of an MMF (or an affiliated person of such person) that is subject to Sections 23A and 23B of the Federal Reserve Act to purchase securities from the MMF in reliance on Rule 17a-9 without complying with certain conditions that conflict with those provisions of the Federal Reserve Act. This relief is subject to additional conditions that are specified in the ICI Letter and will cease to be in effect upon notice from the Staff.
The ICI Letter is available here: https://www.sec.gov/investment/investment-company-institute-031920-17a.