IMMFA: Membership Information

The Institutional Money Market Funds Association (IMMFA) is the trade association representing the providers of, and providers of services to, triple-A rated money market funds domiciled in the EU and Switzerland.  IMMFA has 36 members: twenty-nine are Full members, ie fund providers, and seven are Associate members, providing services to the funds. Established on 14 June 2000, IMMFA represents approximately 85% of the European 2a-7 style funds industry. IMMFA members’ funds under management was approximately US$ 622 billion at end of April 2008. (Source iMoneyNet) 

IMMFA has three principal objectives namely:

1. To ensure that members offer a high quality product and service to investors.
2. To lobby governments, regulators and other policymakers for appropriate treatment of institutional money market funds.
3. To provide generic information about the industry to investors.

1. Ensure that members offer a high quality service to investors

In this regard IMMFA funded a no-names study by an independent industry specialist to review and report on the administration and pricing practices undertaken by both Fund Administrators and investment managers on behalf of member funds. As a result, a number of recommendations were made which we are now in the process of implementing.  The study provided the basis of IMMFA's Industry Guide to Understanding Institutional Money Market Funds (attached).

2. Lobby governments, regulators and other policymakers for appropriate treatment of institutional money market funds

We had direct input to Brussels on the revised proposals for capital adequacy regarding investments in collective investment schemes.  Other key issues include the treatment of Money Market Instruments as part of the CESR review of Eligible Assets and clarification of the appropriate accounting treatment for Money Market Funds under International Accounting Standards.

3. Provide generic information about the industry to investors

IMMFA is increasingly becoming recognised by many investors as a quality 'kitemark' for the industry and liability insurance purposes. This is likely to increase as the reliance on external ratings becomes more important under the Capital Requirements Directive.

The cost of membership is £10,000 per annum but normally qualifies as an eligible expense to be met out of the gross income of funds since the three principal objectives of IMMFA have benefits for all investors.

IMMFA Members play an active part in establishing the programme of work for the Association.  The members meet regularly, at twice-yearly members meetings and at quarterly Distribution and Technical Committee meetings. The Association is run by its Board, made up of elected members and of the Chairs of the committees.  The committees, other than the Board, are open to all members to attend.  Should you decide to join, member meetings are usually held at the Investment Management Association offices at 65 Kingsway London on a quarterly basis.

Information is circulated to members via a regular Newsletter and through the members’ part of the website.  Items covered include such things as regulatory and tax issues in different European countries, and business issues that arise from time to time.  IMMFA provides members with opportunities to share information on regulatory developments in other (generally European) countries

A full secretariat service, as well as access to their industry specialists when necessary, is provided through an outsourcing arrangement with the Investment Management Association (IMA).

Some recent activities undertaken by IMMFA

We have established very good relationships with regulators and other official bodies that allow us to put forward our views effectively.  Lobbying is undertaken on behalf of our members and we consult them on the potential impact of the proposed positions/compromises on their businesses.

• IMMFA has had success in lobbying CESR to retain the ability for UCITS funds to use amortised valuation methods.  The loss of this ability would have meant that stable NAV funds in particular would not be able to use UCITS and would instead have had to rely on the 25 different private placement regimes in Europe with associated costs.  IMMFA was the only body to pick up this point. This has now been formalised through the Eligible Assets Directive.
  
• IMMFA successfully lobbied the European Commission to allow client money to be placed in a qualifying money market fund. This is the only product, other than a bank deposit, deemed secure enough to hold client money.
  
• IMMFA lobbied the European Commission to ensure that the highest rated CIUs (thus triple-A rated MMFs) would be treated a falling in the highest capital bucket and thereby be liable for only a 20% capital rating under the CRD.  This gives an equivalent treatment compared with interbank deposits and will allow for a significant expansion of MMFs to European banks from 2007.
  
• IMMFA picked up on the CEBS consultation that would reduce the CRD benefits noted above as CEBS has suggested that the Credit assessment be based solely on a look through to the credit quality of the underlying.  This would mean that no fund would be able to achieve a triple -A rating and would therefore fall to a 50% capital weighting.  We were the only body to identify this concern - we responded to CEBS who amended their guidance to accommodate our concerns.
  
• IMMFA represented the interests of MMF providers to the European Commission consultation on its asset management green  and white papers.

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If you would like details on how to become a member of IMMFA, please contact IMMFA's Secretariat +44 (0) 207 269 4669 or admin@immfa.org