7.16.2008 The SEC staff granted no-action relief that allows Northern Trust Corporation ("NTC") to enter into capital support agreements involving four money market funds: Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio, each of which is a series of the Northern Institutional Funds, and the Money Market Fund, a series of the Northern Funds (each a “Fund” and collectively the “Funds”).
Each Fund seeks to maintain a stable net asset value per share of $I.00 and uses the amortized cost method of valuation in valuing its portfolio securities, as permitted by Rule 2a-7 under the 1940 Act. Each agreement obligates NTC to make a cash contribution to the applicable Fund sufficient to restore the Fund's net asset value (''NAV'') to a specified minimum permissible NAV. NTC is the indirect parent of the Funds’ investment adviser, Northern Trust Investments, N.A. Relief was necessary because NTC is an affiliated person of an affiliated person of the Funds. Transactions and arrangements between first-tier and second-tier affiliated persons and investment companies are generally prohibited by Section 17 of the 1940 Act.
Click http://www.sec.gov/divisions/investment/noaction/2008/northern071608.pdf for a copy of the no-action letter.