Managing 'qualified’ money market funds and complying with all UCITS, MMFR (as UCITS top up) and MiFID II (as MMFR top up) rules requires strict and for an investment fund quite extensive management. A 'qualified' money market fund must meet strict requirements, so that it can be considered as safe as a bank. The intention of the statutory regulation for holding client cash is that this takes place outside the assets of the investment firm and in a transparent and as safe as possible manner.
In addition to regular portfolio management and administration, the fixed costs also cover all (daily) risk and compliance checks and periodic reports to the regulators. The 'qualified' money market funds often trade 'OTC' with counterparties and the valuation of the high-quality money market instruments takes place via special data vendor subscriptions. In addition, FundShare must perform an extensive stress test at least twice a year and additional periodic assessments are made in the field of creditworthiness and liquidity of the underlying money market instruments.
In addition to their own internal controls, the money market funds are supervised to a greater or lesser extent by the custodian (depositary), the independent auditor and the financial supervisors (Autoriteit Financiële Markten and De Nederlandsche Bank).