On March 31, 2009, the Treasury announced another extension of its Temporary Guarantee Program for Money Market Funds until September 18, 2009 to support ongoing stability in the market. Only money market funds that initially participated in the Program and meet the extension conditions and procedural requirements are eligible to continue to participate in the Program. The conditions for a fund’s continued participation in the Program include: (1) no “guarantee event” (i.e., the fund has not “broken the buck” and liquidated) has occurred on or before May 1, 2009, (2) the market-based NAV of the fund on May 1, 2009 is at least $0.995, and (3) the fund’s board, including a majority of the independent directors, determines that the fund’s continued participation in the Program is in the best interests of the fund and its shareholders. The procedural requirements include making an extension payment and submitting an extension notice by April 13, 2009 and a bring-down notice by May 11, 2009. Similar to the prior payments, this extension payment is based on a fund’s NAV as of September 19, 2008. The extension payments are similar to the prior extension payments; the extension payments are 1.5 or 2.3 basis points compared to the 1.5 or 2.25 basis point initial extension payment. The Program as extended would continue to only provide coverage to shareholders on September 19, 2008.  

In order to participate in the Program, a fund had to enter into a Guarantee Agreement with the Treasury. Under the Guarantee Agreement, the Treasury will make a guarantee payment to a fund for its covered shareholders if: (i) the fund’s market-based NAV drops below $0.995 prior to September 18, 2009 (if the fund participates in extension of the Program); (ii) the fund reports this occurrence to the Treasury by the next business day; and (iii) the fund’s board begins the process of liquidating the fund within five business days of the fund’s market-based NAV dropping below $0.995. Any guarantee payments made by the Treasury under the Program cannot exceed the amount of the Exchange Stabilization Fund (the “ESF”), which is the funding vehicle for the Program. The ESF currently has approximately $50 billion in assets. The amount available under the ESF will be reduced by the amounts paid to each fund that breaks the buck and requests a guarantee payment pursuant to the Program. If a fund breaks the buck and requests a guarantee payment on the same day as other money market funds and the amount available in the ESF is not sufficient to meet all requested payments, then the funds will only receive a pro rata share of the available ESF amount. Additionally, under the Guarantee Agreement, the Treasury reserves the right to use the amounts available in the ESF, including funds held by the ESF that have been designated for use in the Program, for any other purpose. According to the Treasury, as of March 31, 2009, the Program covers over $3 trillion of combined fund assets.