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 Europe.  IMMFA has 34 members: twenty-seven are Full members, ie fund providers, and seven are Associate members, providing services to the funds. Established on 14 June 2000, IMMFA represents approximately 90% of the European 2a-7 style funds industry. IMMFA members’ funds under management was approximately €426 billion as at 26 June 2009. (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 have had direct input to Brussels on the revised proposals for capital adequacy and have formed a working party to test & provide feedback on the latest proposals to ensure that we can provide the level of 'first principle' risk information that banks will require should they decide to invest 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, Technical, Communication and Asian 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 is currently working with the European Fund & Asset Management Association (EFAMA) to develop a pan-European definition of a money market fund. This will address the absence of any definition in Europe, which has resulted in some confusion given the market turmoil which has been experienced in 2007 and 2008.
  
• IMMFA was involved in discussions with the Irish Financial Services Regulatory Authority in the development of its guidance note on the valuation of assets of money market funds. Since its introduction in August 2008, this has restricted to use of the term money market fund and the utilization of amortised accounting to specific funds only, which includes those within the IMMFA membership. 
  
• IMMFA has initiated a review of the money market fund product following the experiences of the autumn of 2008. This will determine whether improvements to the product are necessary, and if so, what those actions should be.
   
• At the height of the market turmoil in 2008, IMMFA initiated discussions with the rating agencies and the Irish Financial Services Regulatory Authority to permit a suspension of the requirement to conduct mark-to-market pricing on assets with a residual maturity of 90 days or less. This was due to the market conditions, and the absence of fair value at that time. 
   
• IMMFA has lobbied for amendments to the Capital Requirements Directive to recognize that banks should be free to determine whether a large exposure arises due to the exposure to a fund or the underlying assets. The proposes amendments - which reflect the IMMFA response - are currently being finalized by the European Parliament prior to implementation.

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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