Tokenized Money Market Funds
Definition
A tokenized money market fund is a money market fund, or a private fund run like one, whose shares are recorded as tokens on public blockchains. The fund invests in short-term government securities and repurchase agreements, aims to keep a stable $1.00 net asset value or accrues income into its price, pays a yield, and redeems shares at net asset value. In the United States a registered money market fund is regulated by Rule 2a-7 under the Investment Company Act, which limits what it can hold, how long its holdings may run, how liquid it must be and how it may price its shares; a private fund that targets $1.00 is not bound by Rule 2a-7 and follows its own offering documents. A tokenized money market fund is a security. A payment stablecoin is a different instrument: a token issued to be redeemed at a fixed value in dollars, backed by reserves, used for payments, and under the GENIUS Act (Pub. L. No. 119-27, 2025) issued by permitted issuers and not treated as a security. The two can sit in the same wallet; they are different legal claims with different protections.
Why it matters
Tokenized money market funds and stablecoins both show a dollar value in a wallet, and the industry markets the former as a yield-bearing version of the latter. The legal reality is that one is an investment fund and the other a payment instrument, and a holder's protections differ accordingly. The fund comes with a portfolio, a manager, a custodian, an auditor and, if registered, the money market fund rules; the stablecoin comes with an issuer's reserves and its redemption promise. Within tokenized funds the line that matters is registration. Franklin's FOBXX, in AltStreet's review, is an SEC-registered government money market fund with a 0.20% net expense ratio, JPMorgan Chase Bank as custodian, PwC as auditor and $686.6 million of net assets at August 31, 2026; it also had five holders owning 74.9% on July 1, 2026, two of them Franklin companies. BlackRock's BUIDL, a BVI private fund targeting a stable $1.00 for qualified purchasers, follows its own documents rather than Rule 2a-7. Both are reasonable products; they are not interchangeable, and neither is a stablecoin.
Common misconceptions
- •A tokenized money market fund is not a stablecoin with yield. It is a fund share; the yield comes from owning the portfolio, and the $1.00 price is a feature of the fund's rules, not a redemption promise by an issuer.
- •Not every tokenized fund that targets $1.00 is a money market fund under Rule 2a-7. Private funds can target $1.00 without its portfolio, liquidity and pricing requirements.
- •Registration does not make the token freely transferable. Registered tokenized funds still restrict transfers to approved wallets and keep transfer-agent control over the register.
- •Concentrated ownership is not unusual early on, but it matters: a few large holders redeeming can change a small fund's size and costs quickly, as FOBXX's 74.9% top-five ownership illustrates.
- •The GENIUS Act carve-out from the securities laws covers payment stablecoins that meet its definition. A token that pays holders a return from a pool of assets is likely a security, whatever it is called.
Technical details
Side by side: registered fund, private fund, stablecoin
Legal claim: registered or private fund token, a share of the fund's portfolio; payment stablecoin, a claim on the issuer to redeem at par.
Regulation: registered money market fund, Investment Company Act and Rule 2a-7, with a public prospectus and monthly Form N-MFP; private fund, Regulation D or offshore rules and its own documents; payment stablecoin, the GENIUS Act and the issuer's supervisor.
Value: registered government fund, stable $1.00 permitted under Rule 2a-7; private fund, a $1.00 target or a rising price, per its documents; stablecoin, par redemption backed by reserves.
Yield to holder: funds pass through portfolio income after fees; payment stablecoin issuers may not pay interest or yield under the GENIUS Act.
Who can hold: funds, eligible and onboarded investors on an allowlist; stablecoins, generally anyone, subject to issuer freezes.
Rule 2a-7 in brief, as it applies to government funds
Portfolio: a government money market fund invests at least 99.5% of its assets in cash, government securities and repurchase agreements collateralized fully by cash or government securities.
Maturity and quality: limits on the maturity of each holding and the portfolio's weighted average maturity and life, and on credit quality.
Liquidity: minimum daily and weekly liquid assets (raised to 25% and 50% by the SEC's 2023 amendments).
Pricing: government and retail funds may maintain a stable $1.00 share price using amortized cost and penny rounding; institutional prime and tax-exempt funds use a floating net asset value.
Fees: the 2023 amendments removed the ability to impose redemption gates and require institutional prime and institutional tax-exempt funds to apply mandatory liquidity fees when daily net redemptions exceed 5%; government funds are not required to impose liquidity fees.
Worked cases
Franklin OnChain U.S. Government Money Fund (FOBXX): the single series of Franklin Templeton Trust; launched April 6, 2021 on Stellar and since added on Polygon, Arbitrum, Avalanche, Ethereum, Aptos, Base and Solana; one share equals one BENJI token at $1.00; dividends declared daily and reinvested as new shares; 0.20% net expense ratio; audited total returns of 2.79% to 5.12% a year since 2023; Franklin Advisers as manager, Western Asset Management as sub-advisor since May 18, 2026, JPMorgan Chase Bank as custodian, PwC as auditor; $686.6 million of net assets at August 31, 2026; 6.91% of shares of record classified as retail in its August 2026 report (AltStreet review of October 4, 2026).
BlackRock USD Institutional Digital Liquidity Fund (BUIDL): a BVI fund targeting a stable $1.00 net asset value (not guaranteed) with daily subscription and redemption in Treasuries and repo; dividends accrue daily and are paid monthly as new tokens; qualified purchasers only; $5,000,000 minimum on the Securitize subscription page while its Form Ds list $100,000 as the minimum accepted from an outside investor; Securitize affiliates act as transfer agent and placement agent (AltStreet Securitize review and Superstate vs Securitize guide, October 2026).
Accumulating comparison: Superstate's USTB, a private Treasury bill fund, accrues income into net asset value per share rather than holding $1.00; see the Tokenized Treasuries page.
Redemption arrangements
Standard: redeem shares with the fund at net asset value; registered funds generally pay within the period their prospectus states, often the same or next business day for government money funds.
On-chain: some issuers let eligible holders redeem by sending tokens to a contract or via the issuer's app, paid in dollars to a linked bank account or in a stablecoin.
Peer-to-peer: transfers between approved wallets at a negotiated price, which can differ from net asset value; FOBXX's documents allow this.
Stress: a registered government fund keeps its liquidity buffers; a private fund relies on its own terms, which may include suspension rights; a stablecoin relies on its issuer's reserves and redemption channel.
Checklist: comparing a tokenized fund with a stablecoin
Legal form: registered fund, private fund, or payment stablecoin; who the issuer is and who regulates it.
Portfolio and reserves: holdings report, custodian, auditor or attestation, and how often each is published.
Value mechanics: $1.00 under Rule 2a-7, a private $1.00 target, a rising price, or par redemption.
Yield: who receives the income on the underlying assets, and after which fees.
Transferability and eligibility: allowlist, minimums, who can redeem, and on which chains the token is native.
Frequently asked questions
- How is a tokenized money market fund different from a stablecoin?
- The fund token is a share in an investment fund: you own part of a portfolio of short-term government debt, earn its yield after fees, and redeem at net asset value, with the fund's board, adviser, custodian and auditor and the securities laws behind it. A payment stablecoin is a claim on its issuer to redeem one token for one dollar, backed by reserves the issuer holds; it is designed for payments, and the GENIUS Act bars permitted payment stablecoin issuers from paying interest or yield to holders. One is an investment that can lose value in principle; the other is a payment instrument whose value depends on the issuer's reserves and redemption.
- Can a tokenized money market fund lose its $1.00 value?
- In principle, yes. A registered government money market fund may use a stable $1.00 price under Rule 2a-7 because it holds almost entirely cash, government securities and repo backed by them, but its prospectus says it could lose money. A private fund targeting $1.00, such as BlackRock's BUIDL, states that the stable value is not guaranteed. Government money funds have rarely broken $1.00; the risk is low, not zero, and it is different from a stablecoin's risk, which is the issuer's reserves and redemption.
- Are tokenized money market funds registered with the SEC?
- Some are. Franklin's FOBXX is a series of Franklin Templeton Trust, registered under the Investment Company Act, with a public prospectus, monthly Form N-MFP reports and PwC-audited annual reports. Many others are private funds sold to qualified purchasers under Regulation D or to non-US investors offshore, which publish less and are not bound by Rule 2a-7. Both kinds are securities; the registered kind carries the money market fund rules and disclosure.
- How does a tokenized money market fund pay its yield?
- Either by issuing more tokens or by raising the token's price. FOBXX declares dividends daily and reinvests them as new shares at $1.00, so the holder's token balance grows; BlackRock's BUIDL accrues dividends daily and pays them monthly as new tokens. Funds that do not target $1.00 let the price per token rise. A stablecoin pays nothing to holders; any return on its reserves goes to the issuer.
- Can I send a tokenized money market fund token to anyone?
- Usually only to approved wallets. Tokenized funds keep an allowlist so that the register contains only identified, eligible holders. FOBXX permits peer-to-peer transfers between approved wallets, which can occur at a separately negotiated price, and its prospectus keeps the transfer agent's control over and right to correct the register. Stablecoins are generally transferable to any wallet, subject to the issuer's freeze powers.
- Which is better for holding cash on-chain?
- They serve different purposes. A stablecoin is for paying and settling: transferable to anyone, accepted widely, earning nothing for the holder. A tokenized money market fund is for holding: it earns the short-term government rate less fees, but only eligible holders can hold and redeem it, and transfers are restricted. Many holders use both, keeping working balances in a stablecoin and idle balances in a fund token, with the conversion costs and timing that adds.
