Cavanal Hill Funds Sec Money Market Fund Reform Announcement

September 7, 2023

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In July 2023, the United States Securities and Exchange Commission (the “SEC”) adopted new rules affecting money market funds. The new rules will become effective October 2023, with a tiered transition period for funds to begin complying with different rules. Cavanal Hill Funds (“CHF”) has spent a significant amount of time reviewing the reforms, a summary of which is provided below.

The new rules substantially increase the minimum liquidity requirements applicable to money market funds. Previously, money market funds were required to keep 10% of the fund’s assets in daily liquid assets and 30% in weekly liquid assets. After the new rules go into effect, the daily and weekly minimum liquidity requirement will increase to 25% and 50%, respectively. This substantial increase in minimum liquidity requirements will require CHF to alter its internal stress tests. However, at present, the Cavanal Hill Money Market Funds operate well above the new thresholds and will not be required to make significant adjustments in complying with the new minimumThe new rules also remove a money market fund’s ability to impose temporary gates to suspend redemptions. Further, the new rules also remove a regulatory tie permitting money market funds to impose certain liquidity fees if weekly liquid assets fall below a certain threshold. These changes are designed to reduce the risk that investors make a run on money market funds during times of increased market stress.

The most significant change the new rules bring are rules permitting money market funds to handle negative interest rate environments either (i) by converting from a stable share price to a floating share price or (ii) by reducing the total number of outstanding shares, each of which are designed to maintain a stable Net Asset Value (“NAV”) per share. The forgoing changes are, as always, subject to the Board of Trustees making certain determinations and making certain disclosures to money market fund investors.

Finally, the new rules modify reporting requirements. The modified reporting requirements are designed to improve transparency with respect to the figures affected by the new rules (minimum liquidity requirements, etc.) and will permit the SEC to better monitor money market fund activity. The changes in the reporting requirements will be managed by Citi Fund Services, CHF’s sub-administrator.

Cavanal Hill Funds will keep you informed of any additional changes and will continue to manage the Funds to accomplish the individual Fund objectives described in the statutory prospectus, which can be found at www.cavanalhillfunds.com.

If you require additional information, please contact Bill King at 918.382.5491 or at bill.king@cavanalhill.com. You may find useful information in the press release issued by the SEC describing the money market fund reforms, which may be viewed here: https://www.sec.gov/news/press-release/2023-129.

DISCLOUSRES

An investor should consider a fund’s investment objectives, risks and charges and expenses carefully before investing or sending money This and other important information about an investment company can be found in the fund’s prospectus. To obtain a Cavanal Hill Funds prospectus or summary prospectus, please call 800-762-7085 or visit us at www.cavanalhillfunds.com. Please read it carefully before investing.

Cavanal Hill Investment Management, Inc. is an SEC registered investment adviser and a wholly-owned subsidiary of BOK Financial Corporation, a financial holding company (“BOKF”). BOKF, NA serves as the custodian for the Cavanal Hill Funds. Cavanal Hill Investment Management, Inc. provides investment advice, administration and other services for the Funds and receives a fee for providing such services as fully described in the prospectus. The Funds are distributed by Cavanal Hill Distributors, Inc. a registered Broker/Dealer, member FINRA and wholly-owned subsidiary of BOKF

You could lose money by investing in the Fund. Although the Fund seeks to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. An investment in the Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. The Fund’s sponsor has no legal obligation to provide financial support to the Fund, and you should not expect that the sponsor will provide financial support to the Fund at any time.

Commentary provided is for the indicated period and is designed to provide a frame of reference. It does not constitute investment advice. Information contained herein has been obtained from sources believed to be reliable, but not guaranteed. The opinions expressed herein reflect the judgment of the authors at this date and are subject to change without notice and are not a complete analysis of any sector, industry or security. This document contains forward-looking statements that are based on management’s beliefs, assumptions, current expectations, estimates and projections about the Cavanal Hill Funds, the securities and credit markets and the economy in general. Words such as “anticipates,” “believes,” “estimates,” “expects,” “forecasts,” “plans,” “projects,” variations of such words and similar expressions are intended to identify such forward-looking statements. Management judgments relating to and discussion of the value and potential future value or performance of any security, group of securities, type of security or market segment involve judgments as to expected events are inherently forward-looking statements. Management judgments relating to and discussion of the value and potential future value or performance of any security, group of securities, type of security, group of securities, type of security or market segment involve certain risks, uncertainties and assumptions that are difficult to predict with regard to timing, extent, likelihood and degree of occurrence. Therefore, actual results and outcomes may materially differ from what is expressed, implied, or forecasted in such forward-looking statements. The potential realization of these forward-looking statements is subject to a number of limitations and risks, which are described in the Fund’s prospectuses, and investors or potential investors, are cautioned to review the Funds’ prospectuses and the description of such risks. Neither the Funds nor the Funds’ investment adviser, Cavanal Hill, undertake any obligation to update, amend, or clarify forward-looking statement, whether as a result of new information, future events or otherwise.