Removal of Certain References to Credit Ratings Under the Investment Company Act

The Securities and Exchange Commission ("Commission') is adopting amendments to a rule and three forms under the Investment Company Act of 1940 ("Investment Company Act') and the Securities Act of 1933 ("Securities Act') in order to implement a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act'). Specifically, rule 5b-3 under the Investment Company Act contains a reference to credit ratings in determining when an investment company ("fund') may treat a repurchase agreement as an acquisition of securities collateralizing the repurchase agreement for certain purposes under the Investment Company Act. The amendments we are adopting today replace this reference to credit ratings with an alternative standard designed to retain a similar degree of credit quality to that in current rule 5b-3. The Commission is also adopting amendments to Forms N-1A, N-2, and N-3 under the Investment Company Act and Securities Act to eliminate the required use of NRSRO credit ratings when a fund chooses to depict its portfolio holdings by credit quality.