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NUMBER OF MONEY FUNDS WAIVING FEES HAS DECLINED

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If a money-market mutual fund isn't returning quite what you were hoping for at the moment, the explanation may go deeper than the latest ups and downs of interest rates.

Just possibly its manager has discontinued, or decided against, a policy of waiving expense and management fees, which otherwise would have resulted in a higher yield to investors.For most of the 1990s, as interest rates fell, more and more money funds waived some or all of their fees, competing to attract and keep investors who were tempted to look elsewhere for places to put their cash reserves.

But in recent months, according to IBC-Donoghue Inc., an Ashland, Mass. firm that tracks the money-fund business, that trend has shown signs of reversing itself.

Donoghue's Quarterly Report on Money Fund Performance for the April-June period found the percentage of all money funds waiving some or all of their fees declined to 57 percent from the record high of 60.2 percent reached last winter.

The firm counted 48 funds that stopped waiving part or all of their fees during the second quarter.

"Fund companies have aggressively sought to attract assets by waiving fees," said Teresa Redinger, the report's editor.

"Now with interest rates on the rise and money funds showing more favorable yields, this marketing approach isn't as essential as it had been in the past to boost a fund's yield. Additionally, newly introduced funds are not as apt to consider waiving."

Money funds' average seven-day yield, as reported by IBC Donoghue, stood at 3.83 percent in early August, up from 2.65 percent a year earlier.

Over that same span, yields offered by competing vehicles at banks - money-market deposit accounts and short-term certificates of deposit - have risen much more slowly.

Also, fixed-income funds with longer maturities, ranging from short-term bond funds to bond funds with average maturities of 20 years or more, look less appetizing to investors after having been rocked by this year's price volatility in the credit markets. Most stock funds have also struggled so far in 1994.

So the competitive pressures on money funds have eased, giving them more leeway in their fee policies.

This is not to say that money-fund fees have suddenly ballooned. By Donoghue's tally for the second quarter, they averaged 58 basis points, or .58 percentage point, per year.

That matched the record low they reached in the first quarter, down two basis points from where they stood in the second quarter of 1993.

But if the drive to waive fees had kept its momentum, quite possibly fees would have gone lower still, leaving more money from interest received by the funds to be paid out as dividends to shareholders.

Whatever happens with fee waivers in the future, the current situation makes clear that policies on this subject bear scrutiny when you choose a money fund in the first place, and for as long as you keep an account there.

"Watch out for fee waivers," urges Mark Green, New York City's public advocate, in a report on fund prospectuses.

"Some funds voluntarily pay some of the fees instead of passing them on to you. This lets them advertise a higher yield.

"But prospectuses rarely tell you when this generosity will run out. If you invest after the fee waiver expires, your returns will likely be lower than advertised."