Cash & Liquidity Management

Time to get your house in order: Gearing up for European Money Market Fund (MMF) Regulation

Published: Sep 2017
J.P. Morgan Asset Management Thought for the Month – building stronger liquidity strategies – let's solve it.

September 2017

Two months on from the finalisation of the European MMF Regulation, it’s all too easy to feel that implementation in January 2019 is a long way off. But, as a treasurer, taking a proactive approach to thinking ahead can position you to make the most of the opportunities that the regulation will bring. So what do you need to do? And, crucially, when do you need to do it?

There’s still plenty of time to tackle the implications of European MMF regulation for your organisation, but it’s important to start planning now. Let’s break things down into three manageable chunks, beginning with the steps you need to consider between now and the end of this year.

First, start by getting to grips with the detail of the regulation itself. As part of this process, you’ll need to make sure all internal stakeholders understand exactly what the regulation entails and what the changes mean for your organisation. You’ll also need to define the cash that could fall within the scope of the regulation.

What’s next? In the first half of 2018, think about reviewing your investment policy and decide if you need to make changes in order to take full advantage of all the options available under the new rules. Some of the new rules require changes to the funds’ constitutional documents, so your MMF client advisor may ask you to vote on the changes by post at an extraordinary general meeting. This is a functional requirement that enables the regulation to be implemented. You’ll also need to think through any implications for accounting platforms and treasury workstations, and engage with trading portals and sweep platforms as appropriate.

And finally, in the second half of 2018, you must be ready to communicate your decision on the options that best suit your cash requirements, as MMF sponsors will likely be looking to convert their funds to the new regulation during the final quarter of 2018, ahead of the deadline. This is also your chance to test and review all changes to your internal processes and system ahead of implementation in January 2019.

We’re very happy to help you prepare for meetings with your board or senior management. You’re also welcome to contact your MMF client advisor or explore the implications of the regulation at J.P. Morgan Asset Management’s European MMF Reform Resource Centre.

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