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Primers· Collateral & margin

What is a tokenised money market fund, and how is it different from a stablecoin?

A tokenised MMF is a share in a regulated fund recorded or represented on a ledger. A stablecoin is a payment token. They look alike on a screen, but they behave differently in collateral, settlement and default.

Published
17 October 2026
Author
Simo Lamine
Regions
Global
Reading time
3 min

The short answer

  • A money market fund invests in short-term, high-quality assets such as Treasury bills, certificates of deposit, commercial paper and bank deposits [5]. A US government money market fund holds at least 99.5% of its assets in cash, government securities and fully collateralised repo [6]. Investors own shares or units in the fund and subscribe and redeem at its net asset value (NAV) per unit [5], struck at set times under fund rules and fund regulation.
  • A tokenised MMF is the same fund, or a share class of it, with its units recorded or represented on a distributed ledger.
  • A stablecoin is a crypto-asset that aims to keep a stable value against a currency or other assets [10]. Under the US GENIUS Act, which takes effect by January 2027 at the latest, a payment stablecoin's issuer must redeem it “for a fixed amount of monetary value” and hold reserves backing it at least one to one [8]. In the EU, the equivalent token referencing a single currency is an e-money token [9].

Three ways a fund can be "tokenised"

Model What the token is Which record is legal title Example
On-chain register The fund's own register of units is kept on a ledger The ledger UK guidance now says that where an authorised fund keeps its unitholder register on DLT, the on-chain record of transactions may be treated as the primary books and records [1]
Transfer agent's record, with the blockchain as a copy or part of the system Units recorded on a blockchain, alongside or inside the transfer agent's system The transfer agent's record Fidelity's OnChain share class: the book-entry record is official and the blockchain is a secondary record [3]. Franklin Templeton's fund: the transfer agent keeps the official record in a blockchain-integrated system [4]
Mirror token A token that mirrors a holding kept elsewhere The conventional books and records BNY and Goldman Sachs: BNY keeps the official books and records [2]

For collateral, this table matters more than anything else. A pledge or a title transfer has to act on the record that counts in law. Where the blockchain is only a copy, it can lag: Fidelity's prospectus warns that the on-chain record “may not represent an investor’s then-current ownership balance” [3].

Tokenised MMF or stablecoin?

Tokenised MMF Stablecoin
What you hold A share in a regulated investment fund [5] A claim on the issuer [9]
Value Some funds, such as the US government funds above, aim for a stable $1.00 share price but do not guarantee it [3] [4]; others move with the NAV [5] [6]. For stable-price funds, US advertising must state that the fund “cannot guarantee it will do so” [7] Aims to stay fixed at one unit of currency [8] [9]
Income Earns the fund's yield, after fees None from issuers regulated under MiCA, which bars interest; the GENIUS Act imposes the same ban once it takes effect, by January 2027 at the latest [8] [9]
Getting cash Redeem through the fund's dealing cycle; depending on its rules, the fund may charge liquidity fees or suspend redemptions [4] Redeem with the issuer: in the EU at any time, at par and without a fee [9]; in the US, once the GENIUS Act applies, under the issuer's published redemption policy [8]
Who can hold it Usually investors approved by the transfer agent, using permissioned wallets [3] [4] Depends on the issuer and the venue
Typical collateral use (examples) Margin for OTC derivatives and repo, where the fund is eligible [11] Settlement asset and margin on some trading venues

Why it matters for post-trade

  • For collateral teams: tokenised MMF units can move as collateral without first being redeemed [11]. The questions are eligibility, control, valuation, the cash leg and the path to cash. See our deep dive: Tokenised money market funds as collateral, and our tracker.
  • For technology teams: fund dealing is asynchronous (request, cut-off, NAV strike, settlement), so the ledger has to model dealing days rather than instant swaps. See our Lab: A tokenised MMF pledged as CCP margin.

Sources

  1. 1FCA, PS26/7: Progressing fund tokenisation, 30 April 2026.
  2. 2BNY, BNY and Goldman Sachs launch tokenized money market funds solution, 23 July 2025.
  3. 3Fidelity Hereford Street Trust (SEC filing), Fidelity Treasury Digital Fund prospectus, OnChain class (Form N-1A, post-effective amendment), 25 July 2025.
  4. 4Franklin Templeton Trust (SEC filing), Franklin OnChain U.S. Government Money Fund prospectus (Form N-1A, post-effective amendment), 1 August 2026.
  5. 5European Union, Regulation (EU) 2017/1131 on money market funds, 14 June 2017.
  6. 6SEC (eCFR), 17 CFR 270.2a-7: Money market funds, read 17 October 2026.
  7. 7SEC (eCFR), 17 CFR 230.482: Advertising by an investment company, read 17 October 2026.
  8. 8US Congress, GENIUS Act (Public Law 119-27), 18 July 2025.
  9. 9European Union, Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), 31 May 2023.
  10. 10Financial Stability Board, High-level Recommendations for the Regulation, Supervision and Oversight of Global Stablecoin Arrangements: Final report, 17 July 2023.
  11. 11The TRADE, JP Morgan's tokenised collateral platform sees first live settlement through BlackRock and Barclays, 11 October 2023.

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