-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, V2I+WvvDj/So7R+gLdOsTMUKpT4NX3yqQBInaVvJNhq2ztzIyNHoyNSuTn5nii28 +LP57FCMTJbOnXeCemLAmw== 0000088053-05-000891.txt : 20050804 0000088053-05-000891.hdr.sgml : 20050804 20050804154506 ACCESSION NUMBER: 0000088053-05-000891 CONFORMED SUBMISSION TYPE: N-CSR PUBLIC DOCUMENT COUNT: 10 CONFORMED PERIOD OF REPORT: 20050531 FILED AS OF DATE: 20050804 DATE AS OF CHANGE: 20050804 EFFECTIVENESS DATE: 20050804 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SCUDDER TAX FREE MONEY FUND CENTRAL INDEX KEY: 0000313397 IRS NUMBER: 046438571 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: N-CSR SEC ACT: 1940 Act SEC FILE NUMBER: 811-02959 FILM NUMBER: 05999371 BUSINESS ADDRESS: STREET 1: DEUTSCHE ASSET MANAGEMENT STREET 2: TWO INTERNATIONAL PLACE CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 617-295-3986 MAIL ADDRESS: STREET 1: DEUTSCHE ASSET MANAGEMENT STREET 2: TWO INTERNATIONAL PLACE CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER SHORT TERM MUNICIPAL TRUST DATE OF NAME CHANGE: 19791106 N-CSR 1 tfm.htm ANNUAL REPORT

                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D. C. 20549

                                   FORM N-CSR

Investment Company Act file number 811-2959

                           SCUDDER TAX FREE MONEY FUND
                        --------------------------------
               (Exact Name of Registrant as Specified in Charter)

                 Two International Place, Boston, MA 02110-4103
                 ----------------------------------------------
               (Address of Principal Executive Offices) (Zip Code)

        Registrant's Telephone Number, including Area Code: (212) 454-7190
                                                            --------------

                                  Paul Schubert
                                 345 Park Avenue
                               New York, NY 10154
                     ---------------------------------------
                     (Name and Address of Agent for Service)

Date of fiscal year end:        05/31

Date of reporting period:       05/31/05



ITEM 1.  REPORT TO STOCKHOLDERS


Scudder Tax-Free
Money Fund

 

 

 

Annual Report to Shareholders

 

May 31, 2005

 

Contents

 

Click Here Portfolio Management Review

Click Here Information About Your Fund's Expenses

Click Here Portfolio Summary

Click Here Investment Portfolio

Click Here Financial Statements

Click Here Financial Highlights

Click Here Notes to Financial Statements

Click Here Report of Independent Registered Public Accounting Firm

Click Here Tax Information

Click Here Trustees and Officers

Click Here Account Management Resources

This report must be preceded or accompanied by a prospectus. To obtain a prospectus for any of our funds, refer to the Account Management Resources information provided in the back of this booklet. We advise you to consider the fund's objectives, risks, charges and expenses carefully before investing. The prospectus contains this and other important information about the fund. Please read the prospectus carefully before you invest.

An investment in this fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. A portion of the fund's distributions may be subject to federal, state, local, and the alternative minimum tax. Please read this fund's prospectus for specific details regarding its risk profile.

Scudder Investments is part of Deutsche Asset Management, which is the marketing name in the US for the asset management activities of Deutsche Bank AG, Deutsche Investment Management Americas Inc., Deutsche Asset Management Inc., Deutsche Asset Management Investment Services Ltd., Deutsche Bank Trust Company Americas and Scudder Trust Company.

Fund shares are not FDIC-insured and are not deposits or other obligations of, or guaranteed by, any bank. Fund shares involve investment risk, including possible loss of principal.

Portfolio Management Review

 

tfm_top_margin3Scudder Tax-Free Money Fund: A Team Approach to Investing

Deutsche Investment Management Americas Inc. ("DeIM" or the "Advisor"), which is part of Deutsche Asset Management, is the investment advisor for Scudder Tax-Free Money Fund. DeIM and its predecessors have more than 80 years of experience managing mutual funds and DeIM provides a full range of investment advisory services to institutional and retail clients. DeIM is also responsible for selecting brokers and dealers and for negotiating brokerage commissions and dealer charges.

Deutsche Asset Management is a global asset management organization that offers a wide range of investing expertise and resources. This well-resourced global investment platform brings together a wide variety of experience and investment insight across industries, regions, asset classes and investing styles.

DeIM is an indirect, wholly owned subsidiary of Deutsche Bank AG. Deutsche Bank AG is a major global banking institution that is engaged in a wide range of financial services, including investment management, mutual funds, retail, private and commercial banking, investment banking and insurance.

Portfolio Management Team

A group of investment professionals is responsible for the day-to-day management of the fund. These investment professionals have a broad range of experience in managing money market funds.

In the following interview, Portfolio Manager Joseph Benevento discusses Scudder Tax-Free Money Fund's performance and the market environment for the 12-month period ended May 31, 2005.

Q:  Will you discuss the market environment for the fund during the 12-month period?

A:  Short-term interest rates rose steadily during the fund's reporting period due to the series of interest rate increases by the US Federal Reserve (the Fed). In June 2004, following a substantial improvement in job creation and sharply higher market interest rates, the Fed began to enact what became known as its "measured pace" interest rate policy, moving away from an accommodative stance of low short-term interest rates to try to prevent inflation from accelerating to the point where it would hurt the economy. Under the policy, the Fed increased the federal funds rate by 25 basis points (0.25%) at each of its eight policy meetings over the 12 months ended May 2005. At the close of the fund's fiscal year on May 31, the fed funds rate stood at 3.00%, up from 1.00% at the start of 2004.

In the second half of 2004, the US economy maintained a 4.00% growth rate in the face of rising petroleum prices. As we moved into the fourth quarter of 2004 and the first quarter of 2005, corporate pricing power (the ability of companies to raise prices to boost profits while retaining market share) began to strengthen as inflationary pressures took hold. Monthly job growth remained an economic indicator for the market, but the market's focus gradually shifted to a careful watch for signs of increased inflation. The one-year LIBOR rate, an industry standard for measuring one-year money market rates, closed 2004 at 3.10%, its highest level since March 2002.1 In February 2005, oil prices, which had moderated toward the end of 2004, started to rise once again.

1 LIBOR, the London Interbank Offered Rate, is the most widely used benchmark or reference rate for short-term interest rates. LIBOR is the rate of interest at which banks borrow funds from other banks, in large volume, in the international market.

At the end of May 2005, LIBOR stood at 3.78%. The premium level of LIBOR (which is set by the market) over the fed funds rate (which is fixed by the Federal Reserve) of 3.00% represented the market's concern that the Fed may have to continue raising short-term interest rates to keep inflation under control. It also meant that many market participants had reevaluated their portfolios and sold some riskier issues following announcements of credit problems in the automobile and airline industries. These actions tended to boost yields and depress prices in the credit markets overall.

Another market trend during the second quarter was the split between (1) the Fed's seeming intention to keep raising short-term interest rates and keep consumer prices stable until it achieved what it deemed to be a "neutral" stance (neither specifically encouraging economic growth nor directly fighting inflation) and (2) market disruptions that caused market participants to believe that the Fed would stop raising rates much sooner than previously believed. These events included concerns during April that hedge funds with significant unrealized losses stemming from holdings in automobile bonds had the potential to create enough market instability to alter Fed policy.2,3 Such short-term worries caused the LIBOR rate to dip during mid-April, but the Fed proceeded with its measured policy and raised the fed funds rate at its May 2005 meeting to 3.00%.

2 A hedge fund is a private investment partnership limited to high net worth or institutional investors, often very large, and typically employing high-risk investment strategies.

3 An unrealized loss occurs when the price of a security declines after an investor buys it, but has yet to sell it.

Performance is historical and does not guarantee future results. Current performance may be lower or higher than the performance data quoted.

Fund's Class S Shares Yields

 

7-day current yield

May 31, 2005

2.19%

May 31, 2004

0.41%

Yields are historical, will fluctuate and do not guarantee future performance. The 7-day current yield refers to the income paid by the fund over a 7-day period expressed as an annual percentage rate of the fund's shares outstanding. For the most current yield information, please visit our web sites: myScudder.com or aarp.scudder.com.

Q:  How did the fund perform over its most recent fiscal year, and what has been the strategy for the fund?

A:  For the period, the fund registered favorable performance and achieved its stated objective of providing maximum current income free from federal taxes while maintaining stability of capital. (All performance is historical and does not guarantee future results. Yields fluctuate and are not guaranteed.) As of May 31, 2005, the weighted average maturity of the Tax-Free Money Fund's portfolio was 16 days. During the reporting period, we maintained a cautious stance by shifting the Tax-Free Portfolio's weighted average maturity to a target range of 25 to 30 days. The portfolio also has a targeted allocation of 75% of assets in floating-rate securities and 25% in fixed-rate instruments. In a rising interest rate environment, our strategy — rather than to extend maturity — was to maintain a substantial floating-rate position to provide the fund with flexibility and attractive floating-rate yields. Our decision to maintain a significant floating-rate position generally helped performance during the period. The interest rate of floating-rate securities adjusts

Money market yield curve 5/31/04 versus 5/31/05

tfm_g10k180

Length of Maturity (in months)

This chart is not intended to represent the yield of any Scudder fund. Past performance is no guarantee of future results.

Source: Bloomberg, L.P.

periodically based on indices such as the Bond Market Association Index of Variable Rate Demand Notes.4 Because the interest rates of these instruments can adjust as market conditions change, the instruments can provide flexibility in an uncertain interest rate environment.

4 The Bond Market Association Index of Variable Rate Demand Notes is a weekly high-grade market index produced by Municipal Market Data Group comprising 7-day tax-exempt variable rate demand notes. Actual issues are selected from Municipal Market Data's database of more than 10,000 active issues.

In addition, we continued to focus on the highest-quality investments for the Tax-Free Money Fund's portfolio while seeking competitive yields across the municipal investment spectrum. During the period, the tax-free money markets were forced to adjust to dramatic changes in supply, due to (1) the $15 billion of supply from California's revenue anticipation notes and revenue anticipation warrants that had entered the market back in October 2003, followed by (2) the sudden withdrawal of this supply from the market in June 2004 as California refunded the $15 billion of short-term debt, issuing longer-term debt in its place. It took more than a month for the markets, and tax-exempt interest rates, to adjust after this significant withdrawal of supply. (A severe short-term squeeze on supply tends to push prices of tax-exempt money market securities higher, and their yields significantly lower.) Though we were invested in essential-services bonds (such as those related to water resource/power supply) from California agencies and counties over the period, we avoided adding new state of California issues because of the state's unsettled financial situation.

Another event that created a temporary imbalance in the tax-free money markets was Microsoft's $30 billion dividend paid in December 2004. Because of automated exchanges of some of this money from brokerage accounts into tax-free money market funds, this event created a surge in demand for floating-rate securities and put significant downward pressure on their yields. Eventually, year-end redemptions and new issuance brought supply and demand within the tax-exempt money market back into balance.

In addition, we continued to focus on the highest-quality investments while seeking competitive yields. In particular, we emphasized essential-services revenue issues and what is known as enhanced paper, i.e., securities guaranteed by a third party such as a bank or an insurance company. Finally, as a holder of insured municipal credits, we are carefully monitoring the recent investigations of municipal credit insurer MBIA by securities regulators. MBIA, the largest municipal securities insurance firm, has been the subject of inquiries regarding certain types of derivative securities trading in which it engaged during 2002.

Q:  What detracted from performance during the period?

A:  In December, we kept additional cash on hand — as we do each year — to meet any tax-related redemptions as well as investors' year-end liquidity needs. This detracted somewhat from yield and total return.

Q:  Will you describe your management philosophy?

A:  We continue our insistence on the highest credit quality within the fund. We also plan to maintain our conservative investment strategies and standards. We continue to apply a careful approach to investing on behalf of the fund and to seek competitive tax-free yield for our shareholders.

The views expressed in this report reflect those of the portfolio managers only through the end of the period of the report as stated on the cover. The managers' views are subject to change at any time based on market and other conditions and should not be construed as a recommendation.

Information About Your Fund's Expenses

 

tfm_top_margin2As an investor of the Fund, you incur two types of costs: ongoing expenses and transaction costs. Ongoing expenses include management fees and other Fund expenses. Examples of transaction costs include sales charges (loads), redemption fees and account maintenance fees, which are not shown in this section. The following tables are intended to help you understand your ongoing expenses (in dollars) of investing in the Fund and to help you compare these expenses with the ongoing expenses of investing in other mutual funds. In the most recent six-month period, the Fund limited these expenses for Class AARP; had it not done so, expenses would have been higher. The tables are based on an investment of $1,000 made at the beginning of the six-month period ended May 31, 2005.

The tables illustrate your Fund's expenses in two ways:

Actual Fund Return. This helps you estimate the actual dollar amount of ongoing expenses (but not transaction costs) paid on a $1,000 investment in the Fund using the Fund's actual return during the period. To estimate the expenses you paid over the period, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the "Expenses Paid per $1,000" line under the share class you hold.

Hypothetical 5% Fund Return. This helps you to compare your Fund's ongoing expenses (but not transaction costs) with those of other mutual funds using the Fund's actual expense ratio and a hypothetical rate of return of 5% per year before expenses. Examples using a 5% hypothetical fund return may be found in the shareholder reports of other mutual funds. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period.

Please note that the expenses shown in these tables are meant to highlight your ongoing expenses only and do not reflect any transaction costs. The "Expenses Paid per $1,000" line of the tables is useful in comparing ongoing expenses only and will not help you determine the relative total expense of owning different funds. If these transaction costs had been included, your costs would have been higher.

Expenses and Value of a $1,000 Investment for the six months ended May 31, 2005

Actual Fund Return

Class AARP

Class S

Beginning Account Value 12/1/04

$ 1,000.00

$ 1,000.00

Ending Account Value 5/31/05

$ 1,007.00

$ 1,007.20

Expenses Paid per $1,000*

$ 3.50

$ 3.30

Hypothetical 5% Fund Return

Class AARP

Class S

Beginning Account Value 12/1/04

$ 1,000.00

$ 1,000.00

Ending Account Value 5/31/05

$ 1,021.44

$ 1021.64

Expenses Paid per $1,000*

$ 3.53

$ 3.33

* Expenses are equal to the Fund's annualized expense ratio for each share class, multiplied by the average account value over the period, multiplied by the number of days in the most recent six-month period, then divided by 365.

Annualized Expense Ratios

Class AARP

Class S

Scudder Tax-Free Money Fund

.70%

.66%

For more information, please refer to the Fund's prospectus.

Portfolio Summary May 31, 2005

 

Asset Allocation

5/31/05

5/31/04

 

Municipal Investments

100%

100%

Weighted Average Maturity

 

 

Tax-Free Money Fund

16 days

27 days

National Tax-Free Retail Money Fund Average*

22 days

32 days

* The Fund is compared to its respective iMoneyNet Category: National Tax-Free Retail Money Fund Average — Category consists of all national tax-free and municipal retail funds. Portfolio Holdings of tax-free funds include Rated and Unrated Demand Notes, Rated and Unrated General Market Notes, Commercial Paper, Put Bonds — 6 months & less, Put Bonds — over 6 months, AMT Paper, and Other Tax-Free holdings. Source: iMoneyNet

Asset Allocation is subject to change.

For more complete details about the Fund's holdings, see page 12. A quarterly Fact Sheet is available upon request. Information concerning portfolio holdings of the Fund as of month end will be posted to scudder.com on the 15th of the following month. Please see the Account Management Resources section for contact information.

Following the Fund's fiscal first and third quarter-end, a complete portfolio holdings listing is filed with the SEC on Form N-Q. The form will be available on the SEC's Web site at www.sec.gov, and it also may be reviewed and copied at the SEC's Public Reference Room in Washington, D.C. Information on the operation of the SEC's Public Reference Room may be obtained by calling (800) SEC-0330.

Investment Portfolio as of May 31, 2005

tfm_accompanying_notes0 tfm_top_margin1

 

 

Principal Amount ($)

Value ($)

 

 

Municipal Bonds and Notes 98.6%

Arizona 0.8%

Phoenix, AZ, Industrial Development Authority, Multi-Family Housing Revenue, Centertree Apartments Project, Series A, AMT, 3.02%*, 10/15/2030

1,780,000

1,780,000

Arkansas 1.2%

Pocahontas, AR, Industrial Development Revenue, MacLean Esna LP Project, AMT, 3.1%*, 5/1/2015, Northern Trust Co. (c)

2,500,000

2,500,000

California 1.8%

California, State Department of Water Resources, Power Supply Revenue, Series M5J-D, 144A, 3.07%*, 5/1/2012 (b)

500,000

500,000

California, State Economic Recovery Program, Series C-15, 2.94%*, 7/1/2023 (b)

500,000

500,000

Los Angeles County, CA, Tax & Revenue Anticipation Notes, Series A, 3.0%, 6/30/2005

2,900,000

2,903,175

 

3,903,175

Colorado 2.9%

Adams & Weld Counties, CO, Brighton School District No. 27J, Series RR-II-R-6514, 144A, 3.0%*, 12/1/2024 (b)

2,990,000

2,990,000

Colorado, University Hospital Authority Revenue, Series B, 2.96%*, 11/15/2035, Citibank NA (c)

1,100,000

1,100,000

Summit County, CO, School District No. RE1, Series RR-II-R-6513, 144A, 3.0%*, 12/1/2023 (b)

2,100,000

2,100,000

 

6,190,000

Delaware 0.5%

Delaware, State Economic Development Authority Revenue, Winterthur Museum Project, 3.02%*, 9/1/2012, Wachovia Bank NA (c)

1,000,000

1,000,000

District of Columbia 0.9%

District of Columbia, General Obligation, Series PT-2440, 144A, 2.99%*, 6/1/2024 (b)

1,880,000

1,880,000

Florida 9.1%

Broward County, FL, Educational Facilities Authority Revenue, Nova Southeastern, Series C, 2.99%*, 4/1/2024, Bank of America NA (c)

2,600,000

2,600,000

Florida, Board of Education, Lottery Revenue, Series PT-1952, 144A, 1.7%*, 1/1/2009 (b)

2,545,000

2,545,000

Florida, University Athletic Association, Inc., Capital Improvement Revenue, University of Florida Stadium Project, 3.05%*, 2/1/2020, SunTrust Bank (c)

1,000,000

1,000,000

Miami-Dade County, FL, Industrial Development Authority Revenue, Gulliver Schools Project, 3.01%*, 9/1/2029, Bank of America NA (c)

2,090,000

2,090,000

Orange County, FL, Health Facilities Authority Revenue, Presbyterian Retirement Project, 3.01%*, 11/1/2028, Bank of America NA (c)

5,425,000

5,425,000

Palm Beach County, FL, Health Facilities Authority Revenue, Bethesta Healthcare System Project, 2.99%*, 12/1/2031, SunTrust Bank (c)

500,000

500,000

Pinellas County, FL, Health Facilities Authority Revenue, Hospital Facilities, Bayfront Projects, 2.99%*, 7/1/2034, SunTrust Bank (c)

900,000

900,000

Sarasota County, FL, Utility System Revenue, Series 852, 144A, 3.0%*, 4/1/2013 (b)

4,375,000

4,375,000

 

19,435,000

Georgia 0.9%

Greene County, GA, Development Authority Sewage Facilities Revenue, Carey Station WRF LLC Project, AMT, 3.02%*, 9/1/2024, Wachovia Bank NA (c)

2,000,000

2,000,000

Idaho 1.4%

Power County, ID, Industrial Development Authority, FMC Corp. Project, AMT, 3.02%*, 4/1/2014, Wachovia Bank NA (c)

3,000,000

3,000,000

Illinois 9.8%

Chicago, IL, De La Salle Institution Project, 3.07%*, 4/1/2027, Fifth Third Bank (c)

1,810,000

1,810,000

Illinois, Development Finance Authority Revenue, Museum of Contemporary Art Project, 2.98%*, 2/1/2029, Bank One NA (c)

1,725,000

1,725,000

Illinois, Development Finance Authority, Industrial Development Revenue, Katlaw Tretam & Co. Project, AMT, 3.04%*, 8/1/2027, LaSalle Bank NA (c)

1,700,000

1,700,000

Illinois, Development Finance Authority, Regional Organization Bank Project, 3.06%*, 12/1/2020, Bank One NA (c)

1,600,000

1,600,000

Illinois, Finance Authority Revenue, Series PA-1286, 144A, 2.99%*, 11/15/2023 (b)

3,515,000

3,515,000

Illinois, Sales Tax Revenue, Series R-4516, 144A, 3.0%*, 6/15/2023

4,495,000

4,495,000

Illinois, State General Obligation, 3.0%, 6/3/2005

4,500,000

4,500,236

Vernon Hills, IL, Industrial Development Revenue, Northwestern Tool & Die Project, AMT, 3.08%*, 4/1/2025, Harris Trust & Savings Bank (c)

940,000

940,000

Will & Kendall Counties, IL, Community Consolidated School District No. 202, Series RR-II-R 4031, 144A, 3.0%*, 1/1/2023 (b)

650,000

650,000

 

20,935,236

Indiana 1.1%

Indiana, Transportation/Tolls Revenue, Series R-4528, 144A, 3.0%*, 6/1/2018 (b)

2,285,000

2,285,000

Kentucky 7.6%

Kentucky, Economic Development Finance Authority, Health Facilities Revenue, Easter Seal Society Project, 3.06%*, 11/1/2030, Bank One Kentucky NA (c)

1,180,000

1,180,000

Lexington-Fayette County, KY, Industrial Development Revenue, YMCA Central Kentucky, Inc. Project, 3.08%*, 7/1/2019, Bank One Kentucky NA (c)

2,090,000

2,090,000

Pendleton, KY, County Lease:

 

 

2.85%, 8/5/2005

5,200,000

5,200,000

2.9%, 9/7/2005

7,700,000

7,700,000

 

16,170,000

Louisiana 0.1%

East Baton Rouge Parish, LA, Pollution Control Revenue, Exxon Project, 2.89%*, 3/1/2022

200,000

200,000

Maryland 2.0%

Gaithersburg, MD, Economic Development Revenue, Asbury Methodist Village, 2.99%*, 1/1/2034, KBC Bank NV (c)

4,200,000

4,200,000

Michigan 6.0%

Detroit, MI, Water Supply, ABN AMRO Munitops Certificates Trust, Series 2003-3, 144A, 2.99%*, 1/1/2011 (b)

4,175,000

4,175,000

Michigan, General Obligation, 2.2%, 10/5/2005

2,900,000

2,900,000

Michigan, Municipal Securities Trust Certificates, Series 9054, 144A, 3.0%*, 4/20/2011

3,700,000

3,700,000

Michigan, State Strategic Fund, Limited Obligation Revenue, Merchants LLC Project, AMT, 3.1%*, 3/1/2030, National City Bank (c)

2,000,000

2,000,000

 

12,775,000

Minnesota 1.9%

Elk River, MN, Independent School District No. 728, Series II-R 204, 144A, 3.06%*, 2/1/2015 (b)

200,000

200,000

Minnesota, General Obligation, Public Highway Improvements, Series R-4065, 144A, 3.0%*, 8/1/2023

3,870,000

3,870,000

 

4,070,000

Missouri 0.9%

Missouri, Development Finance Board, Air Cargo Facility Revenue, St. Louis Airport, AMT, 3.04%*, 3/1/2030, American National Bank & Trust (c)

2,000,000

2,000,000

Nebraska 3.5%

Nebraska, Investment Finance Authority, Single Family Housing Revenue, AMT:

 

 

Series D, 3.08%*, 9/1/2034

2,497,500

2,497,500

Series E, 3.08%*, 9/1/2034

4,990,000

4,990,000

 

7,487,500

New Hampshire 1.9%

New Hampshire, Business Finance Authority, Exempt Facilities Revenue, Waste Management of NH, Inc. Project, AMT, 3.02%*, 9/1/2012, Wachovia Bank NA (c)

4,000,000

4,000,000

New Jersey 7.4%

Florham Park, NJ, General Obligation, Board of Education, 3.0%, 7/14/2005

1,898,734

1,901,948

New Jersey, State Tax Anticipation Notes, Series A, 3.0%, 6/24/2005

3,000,000

3,001,952

New Jersey, State Transportation Trust Fund Authority Revenue, Series PT-2494, 144A, 2.99%*, 12/15/2023 (b)

6,200,000

6,200,000

Salem County, NJ, Industrial Pollution Control, Financing Authority Revenue, E.I. Du Pont de Nemours and Co., 2.6%*, 3/1/2012

4,600,000

4,600,000

 

15,703,900

New Mexico 0.9%

New Mexico, State Tax & Revenue Anticipation Notes, Series 2004-A, 3.0%, 6/30/2005

2,000,000

2,001,735

New York 0.7%

New York, State Housing Finance Agency Revenue, 521 West 42nd St. Apartments, AMT, Series A, 2.98%*, 11/1/2034, KeyBank NA (c)

1,574,000

1,574,000

Ohio 0.9%

Ohio, Higher Educational Facilities Community Revenue, Pooled Program:

 

 

Series A, 3.01%*, 9/1/2020, Fifth Third Bank (c)

730,000

730,000

Series B, 3.01%*, 9/1/2020, Fifth Third Bank (c)

1,165,000

1,165,000

 

1,895,000

Pennsylvania 5.7%

Dauphin County, PA, General Authority, Education & Health Loan Program, 3.01%*, 11/1/2017 (b)

4,340,000

4,340,000

Delaware Valley, PA, Regional Finance Authority, Local Government Revenue, Mode 1, 2.96%*, 8/1/2016, Toronto-Dominion Bank (c)

800,000

800,000

Pennsylvania, General Obligation, Series A-15, 144A, 3.0%*, 1/1/2017 (b)

1,645,000

1,645,000

Pennsylvania, State Higher Educational Facilities Authority Revenue, University Properties, Student Housing, Series A, 2.98%*, 8/1/2035, Citizens Bank of PA (c)

5,300,000

5,300,000

 

12,085,000

Puerto Rico 1.4%

ABN AMRO, Munitops, Certificates Trust, Series 2000-17, 144A, 2.96%*, 10/1/2008

3,000,000

3,000,000

South Carolina 0.8%

Marlboro County, SC, Industrial Development Revenue, Reliance Trading Corp. Project, AMT, 3.04%*, 5/1/2017, LaSalle National Bank (c)

1,675,000

1,675,000

Tennessee 0.6%

Montgomery County, TN, Public Building Authority, Pooled Financing Revenue, 2.98%*, 4/1/2032, Bank of America NA (c)

1,180,000

1,180,000

Texas 15.6%

Brazos River, TX, Pollution Control Revenue, Series D-1, AMT, 3.01%*, 5/1/2033, Wachovia Bank NA (c)

2,470,000

2,470,000

Gulf Coast, TX, Waste Disposal Authority, Environmental Facilities Revenue, Waste Corp. Texas Project, AMT, 3.02%*, 9/1/2022, Wells Fargo Bank of Texas NA (c)

960,000

960,000

Harris County, TX, Health Facilities Development Corp. Revenue, The Methodist System, Series B, 2.98%*, 12/1/2032

1,300,000

1,300,000

Plano, TX, Independent School District, Series PT-2428, 144A, 2.99%*, 2/15/2024

5,420,000

5,420,000

San Antonio, TX, Electric & Gas Revenue, Series PT-1706, 144A, 3.0%*, 8/1/2012

1,305,000

1,305,000

Texas, Lower Colorado River Authority, 2.78%, 8/4/2005

3,700,000

3,700,000

Texas, Municipal Power Agency Revenue, Series L36J-D, 144A, 3.07%*, 9/1/2011 (b)

2,000,000

2,000,000

Texas, State Tax & Revenue Anticipation Notes, 3.0%, 8/31/2005

9,850,000

9,876,860

Texas, University of Texas, 2.85%*, 6/3/2005

3,000,000

3,000,000

Waco, TX, Industrial Development Corp., Economic Development Revenue, Patriots Home of Texas Project, AMT, 3.13%*, 6/1/2014, US Bank NA (c)

3,200,000

3,200,000

 

33,231,860

Utah 0.8%

Murray City, UT, Hospital Revenue, IHC Health Services, Inc., Series C, 2.98%*, 5/15/2036

1,700,000

1,700,000

Washington 6.4%

Central Puget Sound, WA, Regional Transit Authority, Sales & Use Tax Revenue, Series 781, 144A, 3.0%*, 11/1/2012 (b)

2,000,000

2,000,000

Washington, General Obligation, Series C-12, 144A, 3.0%*, 1/1/2027 (b)

8,870,000

8,870,000

Washington, State Housing Finance Commission, Multi-Family Revenue, Park Vista Retirement Project, Series A, AMT, 2.96%*, 3/1/2041, Bank of America NA (c)

2,800,000

2,800,000

 

13,670,000

West Virginia 0.1%

Randolph County, WV, Industrial Development Revenue, Allegheny Wood Products Project, AMT, 3.11%*, 12/1/2007, Bank One West Virginia (c)

275,000

275,000

Wyoming 0.2%

Platte County, WY, Pollution Control Revenue, Series B, 3.05%*, 7/1/2014, National Rural Utility Finance (c)

500,000

500,000

Multi-State 2.8%

ABN AMRO, Munitops, Certificates Trust, Series 2003-32, 144A, 3.0%*, 1/15/2012 (b)

5,900,000

5,900,000

 

% of Net Assets

Value ($)

 

 

Total Investment Portfolio (Cost $210,202,406) (a)

98.6

210,202,406

Other Assets and Liabilities, Net

1.4

2,936,040

Net Assets

100.0

213,138,446

* Variable rate demand notes are securities whose interest rates are reset periodically at market levels. These securities are often payable on demand and are shown at their current rates as of May 31, 2005.

(a) The cost for federal income tax purposes was $210,202,406.

(b) Bond is insured by one of these companies:

 

As a % of Total Investment Portfolio

Ambac Financial Group.

7.7

Financial Guaranty Insurance Company

8.8

Financial Security Assurance, Inc.

7.5

MBIA Corp.

3.0

(c) The security incorporates a letter of credit from a major bank.

AMT: Subject to alternative minimum tax

144A: Security exempt from registration under Rule 144A of the Securities Act of 1933. These securities may be resold in transactions exempt from registration, normally to qualified institutional buyers.

The accompanying notes are an integral part of the financial statements.

Financial Statements

 

Statement of Assets and Liabilities as of May 31, 2005

Assets

Investments in securities, at amortized cost

$ 210,202,406

Cash

911,817

Receivable for investments sold

600,046

Interest receivable

1,360,923

Receivable for Fund shares sold

573,300

Other assets

24,382

Total assets

213,672,874

Liabilities

Dividends payable

30,583

Payable for Fund shares redeemed

274,658

Accrued management fee

88,130

Other accrued expenses and payables

141,057

Total liabilities

534,428

Net assets, at value

$ 213,138,446

Net Assets

Net assets consist of:

Undistributed net investment income

83,924

Accumulated net realized gain (loss)

(106,932)

Paid-in capital

213,161,454

Net assets, at value

$ 213,138,446

Net Asset Value

Class AARP

Net Asset Value, offering and redemption price per share ($53,895,305 ÷ 53,952,488 outstanding shares of beneficial interest, $.01 par value, unlimited number of shares authorized)

$ 1.00

Class S

Net Asset Value, offering and redemption price per share ($159,243,141 ÷ 159,039,357 outstanding shares of beneficial interest, $.01 par value, unlimited number of shares authorized)

$ 1.00

The accompanying notes are an integral part of the financial statements.

 

 

Statement of Operations for the year ended May 31, 2005

Investment Income

Income:

Interest

$ 3,701,475

Expenses:

Management fee

1,080,528

Services to shareholders

235,333

Custodian and accounting fees

56,858

Auditing

54,156

Legal

11,499

Trustees' fees and expenses

5,092

Reports to shareholders

29,965

Registration fees

20,291

Other

30,456

Total expenses, before expense reductions

1,524,178

Expense reductions

(62,364)

Total expenses, after expense reductions

1,461,814

Net investment income

2,239,661

Net realized gain from investments

22,888

Net increase (decrease) in net assets resulting from operations

$ 2,262,549

The accompanying notes are an integral part of the financial statements.

 

 

Statement of Changes in Net Assets

Increase (Decrease) in Net Assets

Years Ended May 31,

2005

2004

Operations:

Net investment income

$ 2,239,661

$ 919,435

Net realized gain (loss) on investment transactions

22,888

1,367

Net increase (decrease) in net assets resulting from operations

2,262,549

920,802

Distributions to shareholders from:

Net investment income:

Class AARP

(581,907)

(239,162)

Class S

(1,658,187)

(679,877)

Fund share transactions:

Proceeds from shares sold

95,356,243

93,209,536

Reinvestment of distributions

2,048,856

813,187

Cost of shares redeemed

(107,987,115)

(149,349,029)

Net increase (decrease) in net assets from Fund share transactions

(10,582,016)

(55,326,306)

Increase (decrease) in net assets

(10,559,561)

(55,324,543)

Net assets at beginning of period

223,698,007

279,022,550

Net assets at end of period (including undistributed net investment income of $83,924 and $84,357, respectively)

$ 213,138,446

$ 223,698,007

The accompanying notes are an integral part of the financial statements.

Financial Highlights

 

Class AARP

Years Ended May 31,

2005

2004

2003

2002

2001a

Selected Per Share Data

Net asset value, beginning of period

$ 1.00

$ 1.00

$ 1.00

$ 1.00

$ 1.00

Income from investment operations:

Net investment income

.010

.004

.007

.014

.024

Less distributions from:

Net investment income

(.010)

(.004)

(.007)

(.014)

(.024)

Net asset value, end of period

$ 1.00

$ 1.00

$ 1.00

$ 1.00

$ 1.00

Total Return (%)

1.03b

.37b

.74

1.39

2.50**

Ratios to Average Net Assets and Supplemental Data

Net assets, end of period ($ millions)

54

62

69

76

83

Ratio of expenses before expense reductions (%)

.81

.69

.65

.65

.65*

Ratio of expenses after expense reductions (%)

.70

.67

.65

.65

.65*

Ratio of net investment income (%)

1.01

.36

.74

1.39

3.28*

a For the period from September 11, 2000 (commencement of operations of Class AARP shares) to May 31, 2001.

b Total returns would have been lower had certain expenses not been reduced.

* Annualized

** Not annualized

 

 

Class S

Years Ended May 31,

2005

2004

2003

2002

2001

Selected Per Share Data

Net asset value, beginning of period

$ 1.00

$ 1.00

$ 1.00

$ 1.00

$ 1.00

Income from investment operations:

Net investment income

.011

.004

.007

.014

.034

Less distributions from:

Net investment income

(.011)

(.004)

(.007)

(.014)

(.034)

Net asset value, end of period

$ 1.00

$ 1.00

$ 1.00

$ 1.00

$ 1.00

Total Return (%)

1.07

.37

.74

1.39

3.43a

Ratios to Average Net Assets and Supplemental Data

Net assets, end of period ($ millions)

159

162

210

259

262

Ratio of expenses before expense reductions (%)

.67

.67

.65

.65

.67

Ratio of expenses after expense reductions (%)

.67

.67

.65

.65

.65

Ratio of net investment income (%)

1.04

.36

.74

1.39

3.39

a Total returns would have been lower had certain expenses not been reduced.

Notes to Financial Statements  

 

tfm_top_margin0A. Significant Accounting Policies

Scudder Tax-Free Money Fund (the "Fund") is registered under the Investment Company Act of 1940, as amended (the "1940 Act"), as an open-end, diversified management investment company organized as a Massachusetts business trust.

The Fund offers Class AARP and Class S shares. Shares of Class AARP are designed for members of AARP. Class S shares of the Fund are generally not available to new investors. (Please refer to the Fund's Statement of Additional Information.)

Investment income, realized and unrealized gains and losses and certain fund-level expenses and expense reductions, if any, are borne pro rata on the basis of relative net assets by the holders of both classes of shares, except that both classes bear certain expenses unique to that share class such as shareholder services fees. All shares of the Fund have equal rights with respect to voting subject to class-specific arrangements.

The Fund's financial statements are prepared in accordance with accounting principles generally accepted in the United States of America which require the use of management estimates. Actual results could differ from those estimates. The policies described below are followed consistently by the Fund in the preparation of its financial statements.

Security Valuation. Portfolio securities are valued utilizing the amortized cost method permitted in accordance with Rule 2a-7 under the 1940 Act and certain conditions therein. Under this method, which does not take into account unrealized capital gains or losses on securities, an instrument is initially valued at its cost and thereafter assumes a constant accretion/amortization to maturity of any discount or premium.

Federal Income Taxes. The Fund's policy is to comply with the requirements of the Internal Revenue Code, as amended, which are applicable to regulated investment companies, and to distribute all of its taxable and tax-exempt income to its shareholders. Accordingly, the Fund paid no federal income taxes and no federal income tax provision was required.

During the year ended May 31, 2005, the Fund utilized approximately $23,000 and lost through expiration, $197,000 of prior year capital loss carryforward. At May 31, 2005, the Fund had a net tax basis capital loss carryforward of approximately $107,000, which may be applied against any realized net taxable gains of each succeeding year until fully utilized or until May 31, 2009.

Distribution of Income and Gains. Net investment income of the Fund is declared as a daily dividend and is distributed to shareholders monthly. Net realized gains from investment transactions, in excess of available capital loss carryforwards, would be taxable to the Fund if not distributed, and, therefore, will be distributed to shareholders at least annually.

Permanent book and tax basis differences relating to shareholder distributions will result in reclassifications to paid-in capital. Temporary book and tax basis differences will reverse in a subsequent period. There were no significant book-to-tax differences for the Fund.

At May 31, 2005, the Fund's components of distributable earnings (accumulated losses) on a tax-basis were as follows:

Undistributed tax-exempt income*

$ 114,507

Capital loss carryforwards

$ 107,000

In addition, the tax character of distributions paid to shareholders by the Fund is summarized as follows:

 

Years Ended May 31,

2005

2004

Distributions from tax-exempt income*

$ 2,240,094

$ 919,039

* For tax purposes short-term capital gains distributions are considered ordinary income distributions.

Contingencies. In the normal course of business, the Fund may enter into contracts with service providers that contain general indemnification clauses. The Fund's maximum exposure under these arrangements is unknown as this would involve future claims that may be made against the Fund that have not yet been made. However, based on experience, the Fund expects the risk of loss to be remote.

Other. Investment transactions are accounted for on trade date. Interest income is recorded on the accrual basis. Realized gains and losses from investment transactions are recorded on an identified cost basis. All premiums and discounts are amortized/accreted for both tax and financial reporting purposes.

B. Related Parties

Management Agreement. Under the Management Agreement with Deutsche Investment Management Americas Inc. ("DeIM" or the "Advisor"), an indirect, wholly owned subsidiary of Deutsche Bank AG, the Advisor directs the investments of the Fund in accordance with its investment objectives, policies and restrictions. The Advisor determines the securities, instruments and other contracts relating to investments to be purchased, sold or entered into by the Fund. In addition to portfolio management services, the Advisor provides certain administrative services in accordance with the Management Agreement. The management fee payable under the Management Agreement is equal to an annual rate of 0.50% of the first $500,000,000 of the Fund's average daily net assets and 0.48% of such net assets in excess of $500,000,000, computed and accrued daily and payable monthly. Accordingly, for the year ended May 31, 2005, the fee pursuant to the Management Agreement was equivalent to an annual effective rate of 0.50% of the Fund's average daily net assets.

Effective April 1, 2004 through September 30, 2005, the Advisor has contractually agreed to waive a portion of its fees in Class AARP and Class S of the Fund to the extent necessary to maintain operating expenses of each class at 0.70% of average daily net assets (excluding certain expenses such as extraordinary expenses, taxes, brokerage, interest and trustee and trustee counsel fees).

Service Provider Fees. Scudder Service Corporation ("SSC"), a subsidiary of the Advisor, is the transfer, dividend-paying agent and shareholder service agent for Class AARP and S shares of the Fund. Pursuant to a sub-transfer agency agreement between SSC and DST Systems, Inc. ("DST"), SSC has delegated certain transfer agent and dividend paying agent functions to DST. SSC compensates DST out of the shareholder servicing fee it receives from the Fund. For the year ended May 31, 2005, the amounts charged to the Fund by SSC were as follows:

Services to Shareholders

Total Aggregated


Waived

Unpaid at May 31, 2005

Class AARP

$ 115,817

$ 59,530

$ 18,132

Class S

96,698

23,793

 

$ 212,515

$ 59,530

$ 41,925

Scudder Fund Accounting Corporation ("SFAC"), an affiliate of the Advisor, is responsible for computing the daily net asset value per share and maintaining the portfolio and general accounting records of the Fund. SFAC has retained State Street Bank and Trust Company to provide certain administrative, fund accounting and record-keeping services to the Fund. For the year ended May 31, 2005, the amount charged to the Fund by SFAC for accounting services aggregated $43,756, of which $4,367 is unpaid at May 31, 2005.

Typesetting and Filing Fees. Under an agreement with Deutsche Investment Management Americas Inc. ("DeIM"), an indirect, wholly owned subsidiary of Deutsche Bank AG, DeIM is compensated for providing typesetting and regulatory filing services to the Fund. For the year ended May 31, 2005, the amount charged to the Fund by DeIM included in the reports to shareholders aggregated $8,640, of which $4,320 is unpaid at May 31, 2005.

Trustees' Fees and Expenses. The Fund pays each Trustee not affiliated with the Advisor retainer fees plus specified amounts for attended board and committee meetings.

Other Related Parties. AARP through its affiliate, AARP Services, Inc., monitors and oversees the AARP Investment Program from Scudder Investments, but does not act as an investment advisor or recommend specific mutual funds. DeIM has agreed to pay a fee to AARP and/or its affiliates in return for the use of the AARP trademark and services relating to investments by AARP members in AARP Class shares of the Fund. This fee is calculated on a daily basis as a percentage of the combined net assets of the AARP classes of all funds managed by DeIM. The fee rates, which decrease as the aggregate net assets of the AARP classes become larger, are as follows: 0.07% for the first $6 billion of net assets, 0.06% for the next $10 billion and 0.05% thereafter. These amounts are used for the general purposes of AARP and its members.

Insurance Brokerage Commissions. The Fund paid insurance premiums to an unaffiliated insurance broker in 2002 and 2003. This broker in turn paid a portion of its commissions to an affiliate of the Advisor, which performed certain insurance brokerage services for the broker. The Advisor has reimbursed the Fund for the portion of commissions (plus interest) paid to the affiliate of the Advisor attributable to the premiums paid by the Fund. The amounts for 2002 and 2003 were $111 and $82, respectively.

C. Expense Reductions

For the year ended May 31, 2005, the Advisor agreed to reimburse the Fund $2,622, which represents a portion of the fee savings expected to be realized by the Advisor related to the outsourcing by the Advisor of certain administrative services to an unaffiliated service provider.

In addition, the Fund has entered into an arrangement with its custodian whereby credits realized as a result of uninvested cash balances were used to reduce a portion of the Fund's custodian expenses. During the year ended May 31, 2005, the custodian fee was reduced by $212 for custodian credits earned.

D. Line of Credit

The Fund and several other affiliated funds (the "Participants") share in a $1.1 billion revolving credit facility administered by J.P. Morgan Chase Bank for temporary or emergency purposes, including the meeting of redemption requests that otherwise might require the untimely disposition of securities. The Participants are charged an annual commitment fee which is allocated, based upon net assets, among each of the Participants. Interest is calculated at the Federal Funds Rate plus 0.5 percent. The Fund may borrow up to a maximum of 33 percent of its net assets under the agreement.

E. Share Transactions

The following table summarizes shares and dollar activity in the Fund:

 

Year Ended
May 31, 2005

Year Ended
May 31, 2004

 

Shares

Dollars

Shares

Dollars

Shares sold

Class AARP

9,803,912

$ 9,803,912

11,564,339

$ 11,564,363

Class S

85,552,331

85,552,331

81,645,173

81,645,173

 

 

$ 95,356,243

 

$ 93,209,536

Shares issued to shareholders in reinvestment of distributions

Class AARP

505,267

$ 505,267

203,146

$ 203,146

Class S

1,543,589

1,543,589

610,041

610,041

 

 

$ 2,048,856

 

$ 813,187

Shares redeemed

Class AARP

(18,302,272)

$ (18,302,272)

(19,179,602)

$ (19,179,602)

Class S

(89,684,843)

(89,684,843)

(130,169,427)

(130,169,427)

 

 

$ (107,987,115)

 

$ (149,349,029)

Net increase (decrease)

Class AARP

(7,993,093)

$ (7,993,093)

(7,412,117)

$ (7,412,093)

Class S

(2,588,923)

(2,588,923)

(47,914,213)

(47,914,213)

 

 

$ (10,582,016)

 

$ (55,326,306)

F. Regulatory Matters and Litigation

Since at least July 2003, federal, state and industry regulators have been conducting ongoing inquiries and investigations ("inquiries") into the mutual fund industry, and have requested information from numerous mutual fund companies, including Scudder Investments. It is not possible to determine what the outcome of these inquiries will be or what the effect, if any, would be on the funds or their advisors. Publicity about mutual fund practices arising from these industry-wide inquiries serves as the general basis of a number of private lawsuits against the Scudder funds. These lawsuits, which previously have been reported in the press, involve purported class action and derivative lawsuits, making various allegations and naming as defendants various persons, including certain Scudder funds, the funds' investment advisors and their affiliates, certain individuals, including in some cases fund Trustees/Directors, officers, and other parties. Each Scudder fund's investment advisor has agreed to indemnify the applicable Scudder funds in connection with these lawsuits, or other lawsuits or regulatory actions that may be filed making allegations similar to these lawsuits regarding market timing, revenue sharing, fund valuation or other subjects arising from or related to the pending inquiries. Based on currently available information, the funds' investment advisors believe the likelihood that the pending lawsuits will have a material adverse financial impact on a Scudder fund is remote and such actions are not likely to materially affect their ability to perform under their investment management agreements with the Scudder funds.

Report of Independent Registered Public Accounting Firm

 

To the Trustees and Shareholders of Scudder Tax-Free Money Fund:

In our opinion, the accompanying statement of assets and liabilities, including the investment portfolio, and the related statements of operations and of changes in net assets and the financial highlights, present fairly, in all material respects, the financial position of Scudder Tax-Free Money Fund (the "Fund") at May 31, 2005, and the results of its operations, the changes in its net assets and the financial highlights for each of the periods indicated therein, in conformity with accounting principles generally accepted in the United States of America. These financial statements and financial highlights (hereafter referred to as "financial statements") are the responsibility of the Fund's management; our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits of these financial statements in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits, which included confirmation of securities at May 31, 2005 by correspondence with the custodian, provide a reasonable basis for our opinion.

Boston, Massachusetts
July 22, 2005

PricewaterhouseCoopers LLP

Tax Information (Unaudited)

 

Of the dividends paid from net investment income for the taxable year ended May 31, 2005, 100% are designated as exempt interest dividends for federal income tax purposes.

Please consult a tax advisor if you have questions about federal or state income tax laws, or on how to prepare your tax returns. If you have specific questions about your account, please call 1-800-SCUDDER.

Trustees and Officers

 

The following table presents certain information regarding the Trustees and Officers of the fund as of May 31, 2005. Each individual's year of birth is set forth in parentheses after his or her name. Unless otherwise noted, (i) each individual has engaged in the principal occupation(s) noted in the table for at least the most recent five years, although not necessarily in the same capacity, and (ii) the address of each Trustee is c/o Dawn-Marie Driscoll, PO Box 100176, Cape Coral, FL 33904. Unless otherwise indicated, the address of each Officer is Two International Place, Boston, Massachusetts 02110. The term of office for each Trustee is until the next meeting of shareholders called for the purpose of electing Trustees and until the election and qualification of a successor, or until such Trustee sooner dies, resigns, retires or is removed as provided in the governing documents of the fund. Because the fund does not hold an annual meeting of shareholders, each Trustee will hold office for an indeterminate period. The Trustees of the Fund may also serve in similar capacities with other funds in the fund complex.

Independent Trustees

Name, Year of Birth, Position(s) Held with the Fund and Length of Time Served1

Principal Occupation(s) During Past 5 Years and
Other Directorships Held

Number of Funds in Fund Complex Overseen

Dawn-Marie Driscoll (1946)

Chairman, 2004-present

Trustee, 1987-present

President, Driscoll Associates (consulting firm); Executive Fellow, Center for Business Ethics, Bentley College; formerly, Partner, Palmer & Dodge (1988-1990); Vice President of Corporate Affairs and General Counsel, Filene's (1978-1988). Directorships: CRS Technology (technology service company); Advisory Board, Center for Business Ethics, Bentley College; Board of Governors, Investment Company Institute; former Chairman, ICI Directors Services Committee

42

Henry P. Becton, Jr. (1943)

Trustee, 1990-present

President, WGBH Educational Foundation. Directorships: Becton Dickinson and Company (medical technology company); The A.H. Belo Company (media company); Concord Academy; Boston Museum of Science; Public Radio International. Former Directorships: American Public Television; New England Aquarium; Mass. Corporation for Educational Telecommunications; Committee for Economic Development; Public Broadcasting Service

42

Keith R. Fox (1954)

Trustee, 1996-present

Managing Partner, Exeter Capital Partners (private equity funds). Directorships: Facts on File (school and library publisher); Progressive Holding Corporation (kitchen importer and distributor); Cloverleaf Transportation Inc. (trucking); K-Media, Inc. (broadcasting); Natural History, Inc. (magazine publisher); National Association of Small Business Investment Companies (trade association)

42

Jean Gleason Stromberg (1943)

Trustee, 1999-present

Retired. Formerly, Consultant (1997-2001); Director, US General Accounting Office (1996-1997); Partner, Fulbright & Jaworski, L.L.P. (law firm) (1978-1996). Directorships: The William and Flora Hewlett Foundation; Service Source, Inc.

42

Carl W. Vogt (1936)

Trustee, 2002-present

Senior Partner, Fulbright & Jaworski, L.L.P. (law firm); formerly, President (interim) of Williams College (1999-2000); President, certain funds in the Deutsche Asset Management Family of Funds (formerly, Flag Investors Family of Funds) (registered investment companies) (1999-2000). Directorships: Yellow Corporation (trucking); American Science & Engineering (x-ray detection equipment); ISI Family of Funds (registered investment companies, 4 funds overseen); National Railroad Passenger Corporation (Amtrak); formerly, Chairman and Member, National Transportation Safety Board

42

Officers2

Name, Year of Birth, Position(s) Held with the Fund and Length of Time Served1

Principal Occupation(s) During Past 5 Years and
Other Directorships Held

Julian F. Sluyters4 (1960)

President and Chief Executive Officer, 2004-present

Managing Director3, Deutsche Asset Management (since May 2004); President and Chief Executive Officer of The Germany Fund, Inc., The New Germany Fund, Inc., The Central Europe and Russia Fund, Inc., The Brazil Fund, Inc., The Korea Fund, Inc., Scudder Global High Income Fund, Inc. and Scudder New Asia Fund, Inc. (since May 2004); President and Chief Executive Officer, UBS Fund Services (2001-2003); Chief Administrative Officer (1998-2001) and Senior Vice President and Director of Mutual Fund Operations (1991-1998) UBS Global Asset Management

John Millette (1962)

Vice President and Secretary, 1999-present

Director3, Deutsche Asset Management

Kenneth Murphy (1963)

Vice President, 2002-present

Vice President, Deutsche Asset Management (2000-present); formerly, Director, John Hancock Signature Services (1992-2000)

Paul H. Schubert4 (1963)

Chief Financial Officer, 2004-present

Managing Director3, Deutsche Asset Management (since July 2004); formerly, Executive Director, Head of Mutual Fund Services and Treasurer for UBS Family of Funds at UBS Global Asset Management (1994-2004)

Charles A. Rizzo (1957)

Treasurer, 2002-present

Managing Director3, Deutsche Asset Management (since April 2004); formerly, Director, Deutsche Asset Management (April 2000-March 2004); Vice President and Department Head, BT Alex. Brown Incorporated (now Deutsche Bank Securities Inc.) (1998-1999); Senior Manager, Coopers & Lybrand L.L.P. (now PricewaterhouseCoopers LLP) (1993-1998)

Lisa Hertz4 (1970)

Assistant Secretary, 2003-present

Vice President3, Deutsche Asset Management

Daniel O. Hirsch5 (1954)

Assistant Secretary, 2002-present

Consultant. Formerly, Managing Director, Deutsche Asset Management (2002-2005); Director, Deutsche Asset Management (1999-2002), Principal, BT Alex. Brown Incorporated (now Deutsche Bank Securities Inc.) (1998-1999); Assistant General Counsel, United States Securities and Exchange Commission (1993-1998); Director, Deutsche Global Funds Ltd. (2002-2004)

Caroline Pearson (1962)

Assistant Secretary, 1997-present

Managing Director3, Deutsche Asset Management

Scott M. McHugh (1971)

Assistant Treasurer, 2005-present

Director3, Deutsche Asset Management

Kathleen Sullivan D'Eramo (1957)

Assistant Treasurer, 2003-present

Director3, Deutsche Asset Management

Philip Gallo4 (1962)

Chief Compliance Officer, 2004-present

Managing Director3, Deutsche Asset Management (2003-present); formerly, Co-Head of Goldman Sachs Asset Management Legal (1994-2003)

1 Length of time served represents the date that each Trustee was first elected to the common board of Trustees which oversees a number of investment companies, including the fund, managed by the Advisor. For the Officers of the fund, the length of time served represents the date that each Officer was first elected to serve as an Officer of any fund overseen by the aforementioned common board of Trustees.

2 As a result of their respective positions held with the Advisor, these individuals are considered "interested persons" of the Advisor within the meaning of the 1940 Act. Interested persons receive no compensation from the funds.

3 Executive title, not a board directorship.

4 Address: 345 Park Avenue, New York, New York 10154.

5 Address: One South Street, Baltimore, Maryland 21202.

The fund's Statement of Additional Information ("SAI") includes additional information about the Trustees. The SAI is available, without charge, upon request. If you would like to request a copy of the SAI, you may do so by calling the following toll-free number: 1-800-SCUDDER.

Account Management Resources

 

 

AARP Investment Program Shareholders

Scudder Class S Shareholders

Automated Information Lines

Easy-Access Line

(800) 631-4636

SAILTM

(800) 343-2890

 

Personalized account information, the ability to exchange or redeem shares, and information on other Scudder funds and services via touchtone telephone.

Web Sites

aarp.scudder.com

myScudder.com

 

View your account transactions and balances, trade shares, monitor your asset allocation, and change your address, 24 hours a day.

Obtain prospectuses and applications, blank forms, interactive worksheets, news about Scudder funds, subscription to fund updates by e-mail, retirement planning information, and more.

For More Information

(800) 253-2277

To speak with an AARP Investment Program service representative

(800) SCUDDER

To speak with a Scudder service representative.

Written Correspondence

AARP Investment Program from Scudder Investments

PO Box 219735
Kansas City, MO 64121-9735

Scudder Investments

PO Box 219669
Kansas City, MO 64121-9669

Proxy Voting

A description of the fund's policies and procedures for voting proxies for portfolio securities and information about how the fund voted proxies related to its portfolio securities during the 12-month period ended June 30 is available on our Web sites — aarp.scudder.com or myScudder.com (type "proxy voting" in the search field) — or on the SEC's Web site — www.sec.gov. To obtain a written copy of the fund's policies and procedures without charge, upon request, call your service representative.

Principal Underwriter

If you have questions, comments or complaints, contact:

Scudder Distributors, Inc.

222 South Riverside Plaza
Chicago, IL 60606-5808

(800) 621-1148

 

Class AARP

Class S

Nasdaq Symbol

AFRXX

STFXX

Fund Number

171

071


ITEM 2.         CODE OF ETHICS.

As of the end of the period, May 31, 2005, Scudder Tax Free Money Fund has
adopted a code of ethics, as defined in Item 2 of Form N-CSR, that applies to
its Principal Executive Officer and Principal Financial Officer.

There have been no amendments to, or waivers from, a provision of the code of
ethics during the period covered by this report that would require disclosure
under Item 2.

A copy of the code of ethics is filed as an exhibit to this Form N-CSR.


ITEM 3.         AUDIT COMMITTEE FINANCIAL EXPERT.

The Funds' audit committee is comprised solely of trustees who are "independent"
(as such term has been defined by the Securities and Exchange Commission ("SEC")
in regulations implementing Section 407 of the Sarbanes-Oxley Act (the
"Regulations")). The Funds' Board of Trustees has determined that there are
several "audit committee financial experts" serving on the Funds' audit
committee. The Board has determined that Keith R. Fox, the chair of the Funds'
audit committee, qualifies as an "audit committee financial expert" (as such
term has been defined by the Regulations) based on its review of Mr. Fox's
pertinent experience and education. The SEC has stated that the designation or
identification of a person as an audit committee financial expert pursuant to
this Item 3 of Form N-CSR does not impose on such person any duties, obligations
or liability that are greater than the duties, obligations and liability imposed
on such person as a member of the audit committee and board of directors in the
absence of such designation or identification. In accordance with New York Stock
Exchange requirements, the Board believes that all members of the Funds' audit
committee are financially literate, as such qualification is interpreted by the
Board in its business judgment, and that at least one member of the audit
committee has accounting or related financial management expertise.

ITEM 4.         PRINCIPAL ACCOUNTANT FEES AND SERVICES.


                           SCUDDER TAX FREE MONEY FUND
                      FORM N-CSR DISCLOSURE RE: AUDIT FEES

The following table shows the amount of fees that PricewaterhouseCoopers, LLP
("PWC"), the Fund's independent registered public accounting firm, billed to the
Fund during the Fund's last two fiscal years. For engagements with PWC entered
into on or after May 6, 2003, the Audit Committee approved in advance all audit
services and non-audit services that PWC provided to the Fund.

The Audit Committee has delegated certain pre-approval responsibilities to its
Chairman (or, in his absence, any other member of the Audit Committee).

  Services that the Fund's Independent Registered Public Accounting Firm Billed
                                   to the Fund

- --------------------------------------------------------------------------------
Fiscal Year      Audit       Audit-Related       Tax Fees        All  Other
   Ended      Fees Billed     Fees Billed        Billed to      Fees Billed
  May 31,       to Fund         to Fund            Fund           to Fund
- --------------------------------------------------------------------------------
2005            $50,500           $225            $3,500            $0
- --------------------------------------------------------------------------------
2004            $51,500           $185            $3,300            $0
- --------------------------------------------------------------------------------

The above "Audit- Related Fees" were billed for agreed upon procedures performed
and the above "Tax Fees" were billed for professional services rendered for tax
compliance and tax return preparation.


  Services that the Fund's Independent Registered Public Accounting Firm Billed
              to the Adviser and Affiliated Fund Service Providers

The following table shows the amount of fees billed by PWC to Deutsche
Investment Management Americas, Inc. ("DeIM" or the "Adviser"), and any entity
controlling, controlled by or under common control with DeIM ("Control
Affiliate") that provides ongoing services to the Fund ("Affiliated Fund Service
Provider"), for engagements directly related to the Fund's operations and
financial reporting, during the Fund's last two fiscal years.


- --------------------------------------------------------------------------------
              Audit-Related            Tax Fees             All Other
Fiscal         Fees Billed to          Billed to           Fees Billed
 Year          Adviser and            Adviser and         to Adviser and
 Ended        Affiliated Fund        Affiliated Fund      Affiliated Fund
May 31,      Service Providers      Service Providers    Service Providers
- --------------------------------------------------------------------------------
2005           $581,822                   $0                    $0
- --------------------------------------------------------------------------------
2004           $542,483                   $0                    $0
- --------------------------------------------------------------------------------

The "Audit-Related Fees" were billed for services in connection with the
assessment of internal controls, agreed-upon procedures and additional related
procedures.







                               Non-Audit Services

The following table shows the amount of fees that PWC billed during the Fund's
last two fiscal years for non-audit services. For engagements entered into on or
after May 6, 2003, the Audit Committee pre-approved all non-audit services that
PWC provided to the Adviser and any Affiliated Fund Service Provider that
related directly to the Fund's operations and financial reporting. The Audit
Committee requested and received information from PWC about any non-audit
services that PWC rendered during the Fund's last fiscal year to the Adviser and
any Affiliated Fund Service Provider. The Committee considered this information
in evaluating PWC's independence.


- --------------------------------------------------------------------------------
                                Total
                             Non-Audit
                            Fees billed
                             to Adviser
                                and
                             Affiliated
                            Fund Service             Total
                             Providers             Non-Audit
                            (engagements          Fees billed
                              related             to Adviser
              Total        directly to the      and Affiliated
            Non-Audit      operations and        Fund Service
Fiscal        Fees            financial           Providers
 Year        Billed          reporting            (all other         Total of
 Ended       to Fund        of the Fund)         engagements)        (A), (B)
May 31,        (A)               (B)                  (C)             and (C)
- --------------------------------------------------------------------------------
2005         $3,500              $0                $207,146          $210,646
- --------------------------------------------------------------------------------
2004         $3,300              $0               $1,681,369        $1,684,669
- --------------------------------------------------------------------------------


All other engagement fees were billed for services in connection with risk
management, tax services and process improvement/integration initiatives for
DeIM and other related entities that provide support for the operations of the
fund.

ITEM 5.         AUDIT COMMITTEE OF LISTED REGISTRANTS

                Not Applicable

ITEM 6.         SCHEDULE OF INVESTMENTS

                Not Applicable

ITEM 7.         DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR
                CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

                Not Applicable

ITEM 8.         PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

                Not applicable.

ITEM 9.         PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT
                INVESTMENT COMPANY AND AFFILIATED PURCHASERS

                Not Applicable.

ITEM 10.        SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

The Committee on Independent Trustees/Directors selects and nominates
Independent Trustees/Directors. Fund shareholders may also submit nominees that
will be considered by the committee when a Board vacancy occurs. Submissions
should be mailed to: c/o Dawn-Marie Driscoll, PO Box 100176, Cape Coral, FL
33910.

ITEM 11.        CONTROLS AND PROCEDURES.

(a) The Chief Executive and Financial Officers concluded that the Registrant's
Disclosure Controls and Procedures are effective based on the evaluation of the
Disclosure Controls and Procedures as of a date within 90 days of the filing
date of this report.

(b) There have been no changes in the registrant's internal control over
financial reporting that occurred during the registrant's last half-year (the
registrant's second fiscal half-year in the case of the annual report) that has
materially affected, or is reasonably likely to materially affect, the
registrant's internal controls over financial reporting.

ITEM 12.        EXHIBITS.

(a)(1)   Code of Ethics  pursuant to Item 2 of Form N-CSR is filed and  attached
         hereto as EX-99.CODE ETH.

(a)(2)   Certification  pursuant to Rule 30a-2(a) under the  Investment  Company
         Act of 1940 (17 CFR  270.30a-2(a))  is filed  and  attached  hereto  as
         Exhibit 99.CERT.

(b)      Certification  pursuant to Rule 30a-2(b) under the  Investment  Company
         Act of 1940 (17 CFR  270.30a-2(b))  is furnished and attached hereto as
         Exhibit 99.906CERT.




Form N-CSR Item F

                                   SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, the registrant has duly caused this report to be
signed on its behalf by the undersigned, thereunto duly authorized.

Registrant:                         Scudder Tax Free Money Fund


By:                                 /s/Julian Sluyters
                                    ------------------
                                    Julian Sluyters
                                    Chief Executive Officer

Date:                               August 2, 2005


Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, this report has been signed below by the
following persons on behalf of the registrant and in the capacities and on the
dates indicated.

Registrant:                         Scudder Tax Free Money Fund


By:                                 /s/Julian Sluyters
                                    ------------------
                                    Julian Sluyters
                                    Chief Executive Officer

Date:                               August 2, 2005



By:                                 /s/Paul Schubert
                                    ----------------
                                    Paul Schubert
                                    Chief Financial Officer

Date:                               August 2, 2005

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4ZK;VZN'#> MQYO_?DZ9=>_G.Z=[W<[\I&ONAR_^BQ]//GOY\^CODD[?M6AX]K^=M_V>>'W[ MI_#S0V9;NZ=JT/H%*.!2]@UHX&5&A53@@0PZ]I^"#49XTWP^O=76=%,5M]V# MNTGH(52TY;7@AZG51"))(^J'WXD2IOA2B"S&N%9'_;VVD(LRYHC>B#R>QI2/ M$_6(&I!6F:;CD4@BQ5]V.";I)%T:1A=8DT]6^1>55F:)%Y9:UN?>ES`^QJ65 M8(YY%&S.*>>?@PV6V26#9HX&YIMT&FF5B77FJ>!5\MW(H9Z`@AB?E)H%:BAB M<1ZJ:$N)+NJH28T^JNA[&44J*:#^F6GII8QU=R%X?WJ'(J>D!K46JJIB MR\W7W7#^JQI(*8*Q&E;7IN+AFJ=[M08Y::B]$IA?4<&>IZN.0[$9&9%?OPMNN MN]76JU&:G0[*'4/7UI@IK/[Z^V!OX-D(<,'_TA@EJ&?URW"K^@K<\,(2[Q87 MP@9[&O&&2SI)<+HM!5PEN5ATK)YQKB%[J9GGT1?OQJU<>^331%*XFM=)-0WUU MSVH5C2RZ8*=7])=E)TDEL6D?FMF*;=@:Z\ M-6>`"UWXS6(?[F3BBGM)][R-&VUJY"@S3KF,EE^.&=7,:EZ53M=-S3G0GE,E MN&[[%I9YZ:7U>?+HD#Z^+NM6-[HZ[6WB3B=]!?.LNY;]]MW3EIV/P0F,'FN M(QSD;$:O":8D7@]1U^PJN,$M85!^'P2A!3,8PIR5,%4G!(L&?35"$K:P(2LL M4@HE^$('_@Y'"SH@"B.C0P,RI8=SZ)/A[-:#KPRZZC5I`B*D")BZ'6+,+AYK MXJ`()47C/%$V410=C3:F1>9=L75 GRAPHIC 4 tfmtoin0.gif GRAPHIC begin 644 tfmtoin0.gif M1TE&.#EA5@$M`. GRAPHIC 5 tfmtoin1.gif GRAPHIC begin 644 tfmtoin1.gif M1TE&.#EA5@$M`. GRAPHIC 6 tfmtoin2.gif GRAPHIC begin 644 tfmtoin2.gif M1TE&.#EA5@$M`. GRAPHIC 7 tfmtoin3.gif GRAPHIC begin 644 tfmtoin3.gif M1TE&.#EA5@$M`. EX-99.CODE ETH 8 code_prinofficers0805.txt Scudder/DeAM Funds Principal Executive and Principal Financial Officer Code of Ethics For the Registered Management Investment Companies Listed on Appendix A Effective Date [August, 2005]
Table of Contents Page Number I. Overview.....................................................................................................3 II. Purposes of the Officer Code.................................................................................3 III. Responsibilities of Covered Officers.........................................................................4 A. Honest and Ethical Conduct...................................................................................4 B. Conflicts of Interest........................................................................................4 C. Use of Personal Fund Shareholder Information.................................................................6 D. Public Communications........................................................................................6 E. Compliance with Applicable Laws, Rules and Regulations.......................................................6 IV. Violation Reporting..........................................................................................7 A. Overview.....................................................................................................7 B. How to Report................................................................................................7 C. Process for Violation Reporting to the Fund Board............................................................7 D. Sanctions for Code Violations................................................................................7 V. Waivers from the Officer Code................................................................................7 VI. Amendments to the Code.......................................................................................8 VII. Acknowledgement and Certification of Adherence to the Officer Code...........................................8 IX. Recordkeeping................................................................................................8 X. Confidentiality..............................................................................................9 Appendices...........................................................................................................10 Appendix A: List of Officers Covered under the Code, by Board....................................................10 Appendix B: Officer Code Acknowledgement and Certification Form..................................................11 Appendix C: Definitions..........................................................................................13
2 I. Overview This Principal Executive Officer and Principal Financial Officer Code of Ethics ("Officer Code") sets forth the policies, practices, and values expected to be exhibited in the conduct of the Principal Executive Officers and Principal Financial Officers of the investment companies ("Funds") they serve ("Covered Officers"). A list of Covered Officers and Funds is included on Appendix A. The Boards of the Funds listed on Appendix A have elected to implement the Officer Code, pursuant to Section 406 of the Sarbanes-Oxley Act of 2002 and the SEC's rules thereunder, to promote and demonstrate honest and ethical conduct in their Covered Officers. Deutsche Asset Management, Inc. or its affiliates ("DeAM") serves as the investment adviser to each Fund. All Covered Officers are also employees of DeAM or an affiliate. Thus, in addition to adhering to the Officer Code, these individuals must comply with DeAM policies and procedures, such as the DeAM Code of Ethics governing personal trading activities, as adopted pursuant to Rule 17j-1 under the Investment Company Act of 1940.(1) In addition, such individuals also must comply with other applicable Fund policies and procedures. The DeAM Compliance Officer, who shall not be a Covered Officer and who shall serve as such subject to the approval of the Fund's Board (or committee thereof), is primarily responsible for implementing and enforcing this Code. The Compliance Officer has the authority to interpret this Officer Code and its applicability to particular circumstances. Any questions about the Officer Code should be directed to the DeAM Compliance Officer. The DeAM Compliance Officer and his or her contact information can be found in Appendix A. II. Purposes of the Officer Code The purposes of the Officer Code are to deter wrongdoing and to: o promote honest and ethical conduct among Covered Officers, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; o promote full, fair, accurate, timely and understandable disclosures in reports and documents that the Funds file with or submit to the SEC (and in other public communications from the Funds) and that are within the Covered Officer's responsibilities; o promote compliance with applicable laws, rules and regulations; o encourage the prompt internal reporting of violations of the Officer Code to the DeAM Compliance Officer; and o establish accountability for adherence to the Officer Code. Any questions about the Officer Code should be referred to DeAM's Compliance Officer. - ------------------------ (1) The obligations imposed by the Officer Code are separate from, and in addition to, any obligations imposed under codes of ethics adopted pursuant to Rule 17j-1 under the Investment Company Act of 1940, and any other code of conduct applicable to Covered Officers in whatever capacity they serve. The Officer Code does not incorporate any of those other codes and, accordingly, violations of those codes will not necessarily be considered violations of the Officer Code and waivers granted under those codes would not necessarily require a waiver to be granted under this Code. Sanctions imposed under those codes may be considered in determining appropriate sanctions for any violation of this Code. 3 III. Responsibilities of Covered Officers A. Honest and Ethical Conduct It is the duty of every Covered Officer to encourage and demonstrate honest and ethical conduct, as well as adhere to and require adherence to the Officer Code and any other applicable policies and procedures designed to promote this behavior. Covered Officers must at all times conduct themselves with integrity and distinction, putting first the interests of the Fund(s) they serve. Covered Officers must be honest and candid while maintaining confidentiality of information where required by law, DeAM policy or Fund policy. Covered Officers also must, at all times, act in good faith, responsibly and with due care, competence and diligence, without misrepresenting or being misleading about material facts or allowing their independent judgment to be subordinated. Covered Officers also should maintain skills appropriate and necessary for the performance of their duties for the Fund(s). Covered Officers also must responsibly use and control all Fund assets and resources entrusted to them. Covered Officers may not retaliate against others for, or otherwise discourage the reporting of, actual or apparent violations of the Officer Code or applicable laws or regulations. Covered Officers should create an environment that encourages the exchange of information, including concerns of the type that this Code is designed to address. B. Conflicts of Interest A "conflict of interest" occurs when a Covered Officer's personal interests interfere with the interests of the Fund for which he or she serves as an officer. Covered Officers may not improperly use their position with a Fund for personal or private gain to themselves, their family, or any other person. Similarly, Covered Officers may not use their personal influence or personal relationships to influence decisions or other Fund business or operational matters where they would benefit personally at the Fund's expense or to the Fund's detriment. Covered Officers may not cause the Fund to take action, or refrain from taking action, for their personal benefit at the Fund's expense or to the Fund's detriment. Some examples of conflicts of interest follow (this is not an all-inclusive list): being in the position of supervising, reviewing or having any influence on the job evaluation, pay or benefit of any immediate family member who is an employee of a Fund service provider or is otherwise associated with the Fund; or having an ownership interest in, or having any consulting or employment relationship with, any Fund service provider other than DeAM or its affiliates. Certain conflicts of interest covered by this Code arise out of the relationships between Covered Officers and the Fund that already are subject to conflict of interest provisions in the Investment Company Act and the Investment Advisers Act. For example, Covered Officers may not individually engage in certain transactions (such as the purchase or sale of securities or other property) with the Fund because of their status as "affiliated persons" of the Fund. Covered Officers must comply with applicable laws and regulations. Therefore, any violations of existing statutory and regulatory prohibitions on individual behavior could be considered a violation of this Code. As to conflicts arising from, or as a result of the advisory relationship (or any other relationships) between the Fund and DeAM, of which the Covered Officers are also officers or employees, it is recognized by the Board that, subject to DeAM's fiduciary duties to the Fund, the Covered Officers will in the normal course of their duties (whether formally for the Fund or for DeAM, or for both) be involved in establishing policies and implementing decisions which will have different effects on 4 DeAM and the Fund. The Board recognizes that the participation of the Covered Officers in such activities is inherent in the contract relationship between the Fund and DeAM, and is consistent with the expectation of the Board of the performance by the Covered Officers of their duties as officers of the Fund. Covered Officers should avoid actual conflicts of interest, and appearances of conflicts of interest, between the Covered Officer's duties to the Fund and his or her personal interests beyond those contemplated or anticipated by applicable regulatory schemes. If a Covered Officer suspects or knows of a conflict or an appearance of one, the Covered Officer must immediately report the matter to the DeAM Compliance Officer. If a Covered Officer, in lieu of reporting such a matter to the DeAM Compliance Officer, may report the matter directly to the Fund's Board (or committee thereof), as appropriate (e.g., if the conflict involves the DeAM Compliance Officer or the Covered Officer reasonably believes it would be futile to report the matter to the DeAM Compliance Officer). When actual, apparent or suspected conflicts of interest arise in connection with a Covered Officer, DeAM personnel aware of the matter should promptly contact the DeAM Compliance Officer. There will be no reprisal or retaliation against the person reporting the matter. Upon receipt of a report of a possible conflict, the DeAM Compliance Officer will take steps to determine whether a conflict exists. In so doing, the DeAM Compliance Officer may take any actions he or she determines to be appropriate in his or her sole discretion and may use all reasonable resources, including retaining or engaging legal counsel, accounting firms or other consultants, subject to applicable law.(2) The costs associated with such actions may be borne by the Fund, if appropriate, after consultation with the Fund's Board (or committee thereof). Otherwise, such costs will be borne by DeAM or other appropriate Fund service provider. After full review of a report of a possible conflict of interest, the DeAM Compliance Officer may determine that no conflict or reasonable appearance of a conflict exists. If, however, the DeAM Compliance Officer determines that an actual conflict exists, the Compliance Officer will resolve the conflict solely in the interests of the Fund, and will report the conflict and its resolution to the Fund's Board (or committee thereof). If the DeAM Compliance Officer determines that the appearance of a conflict exists, the DeAM Compliance Officer will take appropriate steps to remedy such appearance. In lieu of determining whether a conflict exists and/or resolving a conflict, the DeAM Compliance Officer instead may refer the matter to the Fund's Board (or committee thereof), as appropriate. However, the DeAM Compliance Officer must refer the matter to the Fund's Board (or committee thereof) if the DeAM Compliance Officer is directly involved in the conflict or under similar appropriate circumstances. After responding to a report of a possible conflict of interest, the DeAM Compliance Officer will discuss the matter with the person reporting it (and with the Covered Officer at issue, if different) for purposes of educating those involved on conflicts of interests (including how to detect and avoid them, if appropriate). Appropriate resolution of conflicts may restrict the personal activities of the Covered Officer and/or his family, friends or other persons. Solely because a conflict is disclosed to the DeAM Compliance Officer (and/or the Board or Committee thereof) and/or resolved by the DeAM Compliance Officer does not mean that the conflict or its resolution constitutes a waiver from the Code's requirements. - ------------------------ (2) For example, retaining a Fund's independent accounting firm may require pre-approval by the Fund's audit committee. 5 Any questions about conflicts of interests, including whether a particular situation might be a conflict or an appearance of one, should be directed to the DeAM Compliance Officer. C. Use of Personal Fund Shareholder Information A Covered Officer may not use or disclose personal information about Fund shareholders, except in the performance of his or her duties for the Fund. Each Covered Officer also must abide by the Funds' and DeAM's privacy policies under SEC Regulation S-P. D. Public Communications In connection with his or her responsibilities for or involvement with a Fund's public communications and disclosure documents (e.g., shareholder reports, registration statements, press releases), each Covered Officer must provide information to Fund service providers (within the DeAM organization or otherwise) and to the Fund's Board (and any committees thereof), independent auditors, government regulators and self-regulatory organizations that is fair, accurate, complete, objective, relevant, timely and understandable. Further, within the scope of their duties, Covered Officers having direct or supervisory authority over Fund disclosure documents or other public Fund communications will, to the extent appropriate within their area of responsibility, endeavor to ensure full, fair, timely, accurate and understandable disclosure in Fund disclosure documents. Such Covered Officers will oversee, or appoint others to oversee, processes for the timely and accurate creation and review of all public reports and regulatory filings. Within the scope of his or her responsibilities as a Covered Officer, each Covered Officer also will familiarize himself or herself with the disclosure requirements applicable to the Fund, as well as the business and financial operations of the Fund. Each Covered Officer also will adhere to, and will promote adherence to, applicable disclosure controls, processes and procedures, including DeAM's Disclosure Controls and Procedures, which govern the process by which Fund disclosure documents are created and reviewed. To the extent that Covered Officers participate in the creation of a Fund's books or records, they must do so in a way that promotes the accuracy, fairness and timeliness of those records. E. Compliance with Applicable Laws, Rules and Regulations In connection with his or her duties and within the scope of his or her responsibilities as a Covered Officer, each Covered Officer must comply with governmental laws, rules and regulations, accounting standards, and Fund policies/procedures that apply to his or her role, responsibilities and duties with respect to the Funds ("Applicable Laws"). These requirements do not impose on Covered Officers any additional substantive duties. Additionally, Covered Officers should promote compliance with Applicable Laws. If a Covered Officer knows of any material violations of Applicable Laws or suspects that such a violation may have occurred, the Covered Officer is expected to promptly report the matter to the DeAM Compliance Officer. 6 IV. Violation Reporting A. Overview Each Covered Officer must promptly report to the DeAM Compliance Officer, and promote the reporting of, any known or suspected violations of the Officer Code. Failure to report a violation may be a violation of the Officer Code. Examples of violations of the Officer Code include, but are not limited to, the following: o Unethical or dishonest behavior o Obvious lack of adherence to policies surrounding review and approval of public communications and regulatory filings o Failure to report violations of the Officer Code o Known or obvious deviations from Applicable Laws o Failure to acknowledge and certify adherence to the Officer Code The DeAM Compliance Officer has the authority to take any and all action he or she considers appropriate in his or her sole discretion to investigate known or suspected Code violations, including consulting with the Fund's Board, the independent Board members, a Board committee, the Fund's legal counsel and/or counsel to the independent Board members. The Compliance Officer also has the authority to use all reasonable resources to investigate violations, including retaining or engaging legal counsel, accounting firms or other consultants, subject to applicable law.(3) The costs associated with such actions may be borne by the Fund, if appropriate, after consultation with the Fund's Board (or committee thereof). Otherwise, such costs will be borne by DeAM. B. How to Report Any known or suspected violations of the Officer Code must be promptly reported to the DeAM Compliance Officer. C. Process for Violation Reporting to the Fund Board The DeAM Compliance Officer will promptly report any violations of the Code to the Fund's Board (or committee thereof). D. Sanctions for Code Violations Violations of the Code will be taken seriously. In response to reported or otherwise known violations, DeAM and the relevant Fund's Board may impose sanctions within the scope of their respective authority over the Covered Officer at issue. Sanctions imposed by DeAM could include termination of employment. Sanctions imposed by a Fund's Board could include termination of association with the Fund. V. Waivers from the Officer Code A Covered Officer may request a waiver from the Officer Code by transmitting a written request for a waiver to the DeAM Compliance Officer.(4) The request must include the rationale for the request and must explain how the waiver would be in furtherance of the standards of conduct described in and underlying purposes of the Officer Code. The DeAM Compliance Officer will present this information - ------------------------ (3) For example, retaining a Fund's independent accounting firm may require pre-approval by the Fund's audit committee. (4) Of course, it is not a waiver of the Officer Code if the Fund's Board (or committee thereof) determines that a matter is not a deviation from the Officer Code's requirements or is otherwise not covered by the Code. 7 to the Fund's Board (or committee thereof). The Board (or committee) will determine whether to grant the requested waiver. If the Board (or committee) grants the requested waiver, the DeAM Compliance Officer thereafter will monitor the activities subject to the waiver, as appropriate, and will promptly report to the Fund's Board (or committee thereof) regarding such activities, as appropriate. The DeAM Compliance Officer will coordinate and facilitate any required public disclosures of any waivers granted or any implicit waivers. VI. Amendments to the Code The DeAM Compliance Officer will review the Officer Code from time to time for its continued appropriateness and will propose any amendments to the Fund's Board (or committee thereof) on a timely basis. In addition, the Board (or committee thereof) will review the Officer Code at least annually for its continued appropriateness and may amend the Code as necessary or appropriate. The DeAM Compliance Officer will coordinate and facilitate any required public disclosures of Code amendments. VII. Acknowledgement and Certification of Adherence to the Officer Code Each Covered Officer must sign a statement upon appointment as a Covered Officer and annually thereafter acknowledging that he or she has received and read the Officer Code, as amended or updated, and confirming that he or she has complied with it (see Appendix B: Acknowledgement and Certification of Obligations Under the Officer Code). Understanding and complying with the Officer Code and truthfully completing the Acknowledgement and Certification Form is each Covered Officer's obligation. The DeAM Compliance Officer will maintain such Acknowledgements in the Fund's books and records. VIII. Scope of Responsibilities A Covered Officer's responsibilities under the Officer Code are limited to: (1) Fund matters over which the Officer has direct responsibility or control, matters in which the Officer routinely participates, and matters with which the Officer is otherwise involved (i.e., matters within the scope of the Covered Officer's responsibilities as a Fund officer); and (2) Fund matters of which the Officer has actual knowledge. IX. Recordkeeping The DeAM Compliance Officer will create and maintain appropriate records regarding the implementation and operation of the Officer Code, including records relating to conflicts of interest determinations and investigations of possible Code violations. 8 X. Confidentiality All reports and records prepared or maintained pursuant to this Officer Code shall be considered confidential and shall be maintained and protected accordingly. Except as otherwise required by law or this Officer Code, such matters shall not be disclosed to anyone other than the DeAM Compliance Officer, the Fund's Board (or committee thereof), legal counsel, independent auditors, and any consultants engaged by the Compliance Officer. 9 Appendices Appendix A: List of Officers Covered under the Code, by Board:
=========================================== ============================== =========================== ============================ Fund Board Principal Executive Principal Financial Treasurer Officers Officers - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Boston Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Chicago Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Closed End (except Germany) Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Korea Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- New York Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- MSIS Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Hedge Strategies Fund Julian Sluyters Alexandra A. Toohey Alexandra A. Toohey - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Germany* Julian Sluyters Paul Schubert Paul Schubert - ------------------------------------------- ------------------------------ --------------------------- ---------------------------- Topiary BPI Julian Sluyters Alexandra A. Toohey Alexandra A. Toohey =========================================== ============================== =========================== ============================
* Central Europe and Russia, Germany, and New Germany Funds DeAM Compliance Officer: Name: Joseph Yuen DeAM Department: Compliance Phone Numbers: 212-454-7443 Fax Numbers: 212-454-4703 As of: August, 2005 10 Appendix B: Acknowledgement and Certification Initial Acknowledgement and Certification of Obligations Under the Officer Code - -------------------------------------------------------------------------------- Print Name Department Location Telephone 1. I acknowledge and certify that I am a Covered Officer under the Scudder Fund Principal Executive and Financial Officer Code of Ethics ("Officer Code"), and therefore subject to all of its requirements and provisions. 2. I have received and read the Officer Code and I understand the requirements and provisions set forth in the Officer Code. 3. I have disclosed any conflicts of interest of which I am aware to the DeAM Compliance Officer. 4. I will act in the best interest of the Funds for which I serve as an officer and have maintained the confidentiality of personal information about Fund shareholders. 5. I will report any known or suspected violations of the Officer Code in a timely manner to the DeAM Compliance Officer. - -------------------------------------------------------------------------------- Signature Date 11 Annual Acknowledgement and Certification of Obligations Under the Officer Code - -------------------------------------------------------------------------------- Print Name Department Location Telephone 6. I acknowledge and certify that I am a Covered Officer under the Scudder Fund Principal Executive and Financial Officer Code of Ethics ("Officer Code"), and therefore subject to all of its requirements and provisions. 7. I have received and read the Officer Code, and I understand the requirements and provisions set forth in the Officer Code. 8. I have adhered to the Officer Code. 9. I have not knowingly been a party to any conflict of interest, nor have I had actual knowledge about actual or apparent conflicts of interest that I did not report to the DeAM Compliance Officer in accordance with the Officer Code's requirements. 10. I have acted in the best interest of the Funds for which I serve as an officer and have maintained the confidentiality of personal information about Fund shareholders. 11. With respect to the duties I perform for the Fund as a Fund officer, I believe that effective processes are in place to create and file public reports and documents in accordance with applicable regulations. 12. With respect to the duties I perform for the Fund as a Fund officer, I have complied to the best of my knowledge with all Applicable Laws (as that term is defined in the Officer Code) and have appropriately monitored those persons under my supervision for compliance with Applicable Laws. 13. I have reported any known or suspected violations of the Officer Code in a timely manner to the DeAM Compliance Officer. - -------------------------------------------------------------------------------- Signature Date 12 Appendix C: Definitions Principal Executive Officer Individual holding the office of President of the Fund or series of Funds, or a person performing a similar function. Principal Financial Officer Individual holding the office of Treasurer of the Fund or series of Funds, or a person performing a similar function. Registered Investment Management Investment Company Registered investment companies other than a face-amount certificate company or a unit investment trust. Waiver A waiver is an approval of an exemption from a Code requirement. Implicit Waiver An implicit waiver is the failure to take action within a reasonable period of time regarding a material departure from a requirement or provision of the Officer Code that has been made known to the DeAM Compliance Officer or the Fund's Board (or committee thereof). 13
EX-99.CERT 9 cert.txt CERTIFICATION Deutsche Asset Management [LOGO] A Member of the Deutsche Bank Group Chief Executive Officer Form N-CSR Certification under Sarbanes Oxley Act I, Julian Sluyters, certify that: 1. I have reviewed this report, filed on behalf of Scudder Tax Free Money Fund, on Form N-CSR; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; 3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report; 4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have: (a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; (b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; (c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and (d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the registrant's most recent fiscal half-year (the registrant's second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and 5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions): (a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and (b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting. August 2, 2005 /s/Julian Sluyters Julian Sluyters Chief Executive Officer Scudder Tax Free Money Fund Deutsche Asset Management [LOGO] A Member of the Deutsche Bank Group Chief Financial Officer Form N-CSR Certification under Sarbanes Oxley Act I, Paul Schubert, certify that: 1. I have reviewed this report, filed on behalf of Scudder Tax Free Money Fund, on Form N-CSR; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; 3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report; 4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have: (a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; (b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; (c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and (d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the registrant's most recent fiscal half-year (the registrant's second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and 5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions): (a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and (b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting. August 2, 2005 /s/Paul Schubert Paul Schubert Chief Financial Officer Scudder Tax Free Money Fund EX-99.906CERT 10 cert906.txt 906 CERTIFICATION Deutsche Asset Management [LOGO] A Member of the Deutsche Bank Group Chief Executive Officer Section 906 Certification under Sarbanes Oxley Act I, Julian Sluyters, certify that: 1. I have reviewed this report, filed on behalf Scudder Tax Free Money Fund, on Form N-CSR; 2. Based on my knowledge and pursuant to 18 U.S.C. ss. 1350, the periodic report on Form N-CSR (the "Report") fully complies with the requirements of ss. 13 (a) or ss.15 (d), as applicable, of the Securities Exchange Act of 1934 and that the information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. August 2, 2005 /s/Julian Sluyters Julian Sluyters Chief Executive Officer Scudder Tax Free Money Fund Deutsche Asset Management [LOGO] A Member of the Deutsche Bank Group Chief Financial Officer Section 906 Certification under Sarbanes Oxley Act I, Paul Schubert, certify that: 1. I have reviewed this report, filed on behalf of Scudder Tax Free Money Fund, on Form N-CSR; 2. Based on my knowledge and pursuant to 18 U.S.C. ss. 1350, the periodic report on Form N-CSR (the "Report") fully complies with the requirements of ss. 13 (a) or ss. 15 (d), as applicable, of the Securities Exchange Act of 1934 and that the information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. August 2, 2005 /s/Paul Schubert Paul Schubert Chief Financial Officer Scudder Tax Free Money Fund -----END PRIVACY-ENHANCED MESSAGE-----