On Tuesday, Oct. 7, 2008, the U.S. Treasury Department and the IRS announced, in Notice 2008-92, that participation by an insurance-dedicated money market fund in the Temporary Guarantee Program for Money Market Funds would not violate the diversification requirement of section 817(h) of the Code. This announcement responded to concerns regarding possible adverse tax consequences for funds in which beneficial interests are held entirely by one or more insurance companies’ segregated asset accounts, were the funds to elect to participate in the program. The notice further stated that the Treasury Department and IRS would not assert that such a fund’s participation in the program causes the holder of a variable contract supported by a segregated asset account that invests in the fund to be treated as an owner of the fund. The Temporary Guarantee Program is described in the Investment Management Alert dated Sept. 30, 2008.