Franklin Resources IncSEC no-action letter facilitates use of Franklin Templeton's on-chain money market fund by registered funds, boosting adoption.

The Investment Management Division of the U.S. Securities and Exchange Commission published a no-action letter on August 12 stating that it would not recommend enforcement action against Franklin Templeton if registered funds invest in the blockchain-based money market fund Franklin OnChain U.S. Government Money Fund for cash management purposes. This makes it easier for existing registered funds such as mutual funds and ETFs to use the on-chain money market fund as a cash management tool. The fund, generally known as BENJI, invests at least 99.5% of its total assets in U.S. government securities, cash, and repurchase agreements fully collateralized by U.S. government securities or cash, and seeks to maintain a net asset value of one dollar per share, although this is not guaranteed. According to the SEC, BENJI uses an integrated recordkeeping system managed by Franklin Templeton Investor Services, Franklin Templeton's registered transfer agent, combining internal bookkeeping systems with transaction records on the blockchain to maintain official shareholder records, and it also has administrative authority to correct erroneous records or unauthorized transactions and to freeze, transfer, or restore records. The staff's view relates to Section 17(f) of the Investment Company Act of 1940 and Rule 17f-2, and states that it would not recommend enforcement action for noncompliance with Rule 17f-2(b), (e), and (f) if certain conditions are met. The letter also makes clear that this is not a legal exemption itself, but a staff view that is not a formal rule or legal determination by the Commission.
Franklin Resources IncSEC no-action letter facilitates use of Franklin Templeton's on-chain money market fund by registered funds, boosting adoption.