UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number 811-06687
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The Gabelli Money Market Funds
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(Exact name of registrant as specified in charter)
One Corporate Center
Rye, New York 10580-1422
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(Address of principal executive offices) (Zip code)
Bruce N. Alpert
Gabelli Funds, LLC
One Corporate Center
Rye, New York 10580-1422
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(Name and address of agent for service)
registrant's telephone number, including area code: 1-800-422-3554
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Date of fiscal year end: September 30
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Date of reporting period: September 30, 2006
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Form N-CSR is to be used by management investment companies to file reports with
the Commission not later than 10 days after the transmission to stockholders of
any report that is required to be transmitted to stockholders under Rule 30e-1
under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may
use the information provided on Form N-CSR in its regulatory, disclosure review,
inspection, and policymaking roles.
A registrant is required to disclose the information specified by Form N-CSR,
and the Commission will make this information public. A registrant is not
required to respond to the collection of information contained in Form N-CSR
unless the Form displays a currently valid Office of Management and Budget
("OMB") control number. Please direct comments concerning the accuracy of the
information collection burden estimate and any suggestions for reducing the
burden to Secretary, Securities and Exchange Commission, 100 F Street, NE,
Washington, DC 20549. The OMB has reviewed this collection of information under
the clearance requirements of 44 U.S.C. ss. 3507.
ITEM 1. REPORTS TO STOCKHOLDERS.
The Report to Shareholders is attached herewith.
THE GABELLI U.S. TREASURY MONEY MARKET FUND
ANNUAL REPORT
SEPTEMBER 30, 2006
TO OUR SHAREHOLDERS,
Our shareholder reports have typically contained commentary on each
portfolio manager's assessment of the economy and how economic events affect
their thinking in managing a specific Fund. We have always provided details
about performance and presented returns, both good and bad, hopefully in a clear
and concise fashion. These comments had been included as part of each Fund's
semi-annual and annual financial statements.
The Sarbanes-Oxley Act's corporate governance regulations require a Fund's
principal executive and financial officers to certify the entire contents of the
semi-annual and annual shareholder reports in a filing with the Securities and
Exchange Commission on Form N-CSR. This certification covers the portfolio
manager's commentary and subjective opinions if they are attached to or a part
of the financial statements.
Rather than ask our portfolio managers to eliminate their opinions and/or
restrict their commentary to historical facts only, we separated their
commentary from the financial statements and investment portfolio and sent it
separately. We will continue to mail the portfolio manager's commentary
separately from the investment portfolio to ensure that its content is complete
and unrestricted. Both the commentary and the financial statements, including
the portfolio of investments, are also available on our website at
www.gabelli.com/funds.
Sincerely yours,
/s/ Bruce N. Alpert
Bruce N. Alpert
Chief Operating Officer
Gabelli Funds, LLC
November 1, 2006
PROXY VOTING
The Fund files Form N-PX with its complete proxy voting record for the 12 months
ended June 30th, no later than August 31st of each year. A description of the
Fund's proxy voting policies, procedures, and how the Fund voted proxies
relating to portfolio securities is available without charge, upon request, by
(i) calling 800-GABELLI (800-422-3554); (ii) writing to The Gabelli Funds at One
Corporate Center, Rye, NY 10580-1422; or (iii) visiting the Securities and
Exchange Commission's (the "SEC") website at www.sec.gov.
PORTFOLIO HOLDINGS
The Fund files a complete schedule of portfolio holdings with the SEC for the
first and third quarters of each fiscal year on Form N-Q, the last of which was
filed for the quarter ended June 30, 2006. Shareholders may obtain this
information at www.gabelli.com or by calling the Fund at 800-GABELLI
(800-422-3554). The Fund's Form N-Q is available on the SEC's website at
www.sec.gov and may also be reviewed and copied at the Commission's Public
Reference Room in Washington, DC. Information on the operation of the Public
Reference Room may be obtained by calling 1-800-SEC-0330.
THE GABELLI U.S. TREASURY MONEY MARKET FUND
DISCLOSURE OF FUND EXPENSES (UNAUDITED)
For the Six Month Period from April 1, 2006 through September 30, 2006
EXPENSE TABLE
================================================================================
We believe it is important for you to understand the impact of fees and expenses
regarding your investment. All mutual funds have operating expenses. As a
shareholder of a fund, you incur ongoing costs, which include costs for
portfolio management, administrative services, and shareholder reports (like
this one), among others. Operating expenses, which are deducted from a fund's
gross income, directly reduce the investment return of a fund. When a fund's
expenses are expressed as a percentage of its average net assets, this figure is
known as the expense ratio. The following examples are intended to help you
understand the ongoing costs (in dollars) of investing in your Fund and to
compare these costs with those of other mutual funds. The examples are based on
an investment of $1,000 made at the beginning of the period shown and held for
the entire period.
The Expense Table below illustrates your Fund's costs in two ways:
ACTUAL FUND RETURN: This section provides information about actual account
values and actual expenses. You may use this section to help you to estimate the
actual expenses that you paid over the period after any fee waivers and expense
reimbursements. The "Ending Account Value" shown is derived from the Fund's
ACTUAL return during the past six months, and the "Expenses Paid During Period"
shows the dollar amount that would have been paid by an investor who started
with $1,000 in the Fund. You may use this information, together with the amount
you invested, to estimate the expenses that you paid over the period.
To do so, 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
given for your Fund under the heading "Expenses Paid During Period" to estimate
the expenses you paid during this period.
HYPOTHETICAL 5% RETURN: This section provides information about hypothetical
account values and hypothetical expenses based on the Fund's actual expense
ratio. It assumes a hypothetical annualized return of 5% before expenses during
the period shown. In this case - because the hypothetical return used is NOT the
Fund's actual return - the results do not apply to your investment and you
cannot use the hypothetical account value and expense to estimate the actual
ending account balance or expenses you paid for the period. This example is
useful in making comparisons of the ongoing costs of investing in the Fund and
other funds. To do so, compare this 5% hypothetical example with the 5%
hypothetical examples that appear in shareholder reports of other funds.
Please note that the expenses shown in the table are meant to highlight your
ongoing costs only and do not reflect any transactional costs such as sales
charges (loads), redemption fees, or exchange fees, if any, which would be
described in the Prospectus. If these costs were applied to your account, your
costs would be higher. Therefore, the 5% hypothetical return is useful in
comparing ongoing costs only, and will not help you determine the relative total
costs of owning different funds. The "Annualized Expense Ratio" represents the
actual expenses for the last six months and may be different from the expense
ratio in the Financial Highlights which is for the year ended September 30,
2006.
Beginning Ending Annualized Expenses
Account Value Account Value Expense Paid During
04/01/06 09/30/06 Ratio Period*
- --------------------------------------------------------------------------------
ACTUAL FUND RETURN
Gabelli U.S. Treasury Money
Market Fund $1,000.00 $1,024.00 0.08% $0.41
HYPOTHETICAL 5% RETURN
Gabelli U.S. Treasury Money
Market Fund $1,000.00 $1,024.67 0.08% $0.41
* Expenses are equal to the Fund's annualized expense ratio for the last six
months multiplied by the average account value over the period, multiplied by
the number of days in the most recent fiscal half-year, then divided by 365.
================================================================================
SUMMARY OF PORTFOLIO HOLDINGS
The following table presents portfolio holdings as a percent of total net assets
as of September 30, 2006:
U.S. TREASURY MONEY MARKET FUND
U.S. Treasury Bills ............................. 87.4%
U.S. Treasury Notes ............................. 12.4%
Assets and Liabilities (Net) .................... 0.2%
------
Net Assets ...................................... 100.0%
======
2
THE GABELLI U.S. TREASURY MONEY MARKET FUND
STATEMENT OF NET ASSETS -- SEPTEMBER 30, 2006
================================================================================
PRINCIPAL MARKET
AMOUNT VALUE
--------- ---------
U.S. GOVERNMENT OBLIGATIONS -- 99.8%
U.S. TREASURY BILLS -- 87.4%
$596,279,000 U.S. Treasury Bills, 4.507% to 5.340%++,
10/05/06 to 03/15/07 ......................... $589,067,547
------------
U.S. TREASURY NOTES -- 12.4%
84,000,000 2.875%, 11/30/06 ............................. 83,719,505
------------
TOTAL U.S. GOVERNMENT OBLIGATIONS .............. 672,787,052
------------
TOTAL INVESTMENTS (Cost $672,787,052) ................... 99.8% 672,787,052
PAYABLE TO MANAGER ...................................... (0.0) (5,101)
DIVIDENDS PAYABLE ....................................... (0.0) (360,366)
PAYABLE FOR TRUSTEES' FEES .............................. (0.0) (59)
OTHER ASSETS AND LIABILITIES (NET) ...................... 0.2 1,467,697
------ ------------
NET ASSETS (applicable to 673,888,617 shares outstanding,
unlimited number of shares authorized) ................ 100.0% $673,889,223
====== ============
NET ASSET VALUE, OFFERING AND REDEMPTION PRICE PER SHARE
($673,889,223 / 673,888,617 shares outstanding) ............. $1.00
=====
NET ASSETS CONSIST OF:
Shares of beneficial interest, at $0.001 par value ........... $ 673,889
Additional paid-in-capital ................................... 673,215,334
------------
TOTAL NET ASSETS ............................................... $673,889,223
============
- ------------------
++ Represents annualized yield at date of purchase.
FINANCIAL HIGHLIGHTS
================================================================================
Selected data for a share of beneficial interest outstanding throughout each
period:
YEAR ENDED SEPTEMBER 30,
-------------------------------------------------------------
2006 2005 2004 2003 2002
-------- -------- -------- ---------- ----------
OPERATING PERFORMANCE:
Net asset value, beginning of period ...................... $ 1.0000 $ 1.0000 $ 1.0000 $ 1.0000 $ 1.0000
-------- -------- -------- ---------- ----------
Net investment income (a) ................................. 0.0426 0.0212 0.0073 0.0095 0.0161
Net realized gain on investments .......................... 0.0000(c) 0.0002 0.0001 0.0002 0.0012
-------- -------- -------- ---------- ----------
Total from investment operations .......................... 0.0426 0.0214 0.0074 0.0097 0.0173
-------- -------- -------- ---------- ----------
DISTRIBUTIONS TO SHAREHOLDERS:
Net investment income ..................................... (0.0426) (0.0212) (0.0073) (0.0095) (0.0161)
Net realized gain on investments .......................... (0.0000)(c) (0.0002) (0.0001) (0.0002) (0.0012)
-------- -------- -------- ---------- ----------
Total distributions ....................................... (0.0426) (0.0214) (0.0074) (0.0097) (0.0173)
-------- -------- -------- ---------- ----------
NET ASSET VALUE, END OF PERIOD ............................ $ 1.0000 $ 1.0000 $ 1.0000 $ 1.0000 $ 1.0000
======== ======== ======== ========== ==========
Total return+ ............................................. 4.33% 2.22% 0.75% 0.98% 1.72%
======== ======== ======== ========== ==========
RATIOS TO AVERAGE NET ASSETS AND SUPPLEMENTAL DATA:
Net assets, end of period (in 000's) ...................... $673,889 $778,298 $925,728 $1,030,710 $1,016,253
Ratio of net investment income to average net assets ...... 4.26% 2.12% 0.73% 0.95% 1.59%
Ratio of operating expenses to average net assets (b) ..... 0.12%(d) 0.30% 0.30% 0.30% 0.30%
- -------------------
+ Total return represents aggregate total return of a hypothetical $1,000
investment at the beginning of the period and sold at the end of the period
including reinvestment of distributions.
(a) Net investment income per share before fees waived by the Manager for the
fiscal years ended September 30, 2006, 2005, 2004, 2003, and 2002 was
$0.0402, $0.0207, $0.0081, $0.0067, and $0.0089, respectively.
(b) Operating expense ratios before fees waived by the Manager for the fiscal
years ended September 30, 2006, 2005, 2004, 2003, and 2002 was 0.36%, 0.35%,
0.36%, 0.36%, and 0.36%, respectively.
(c) Amount represents less than $0.00005 per share.
(d) The Fund incurred interest expense during the fiscal year ended September
30, 2006. If interest expense had not been incurred, the ratio of operating
expenses to average net assets would have been 0.11%.
See accompanying notes to financial statements.
3
THE GABELLI U.S. TREASURY MONEY MARKET FUND
STATEMENT OF OPERATIONS -- YEAR ENDED SEPTEMBER 30, 2006
================================================================================
INVESTMENT INCOME:
Interest .................................................. $ 34,526,284
------------
EXPENSES:
Management fees ........................................... 2,370,232
Shareholder services fees ................................. 143,426
Custodian fees ............................................ 90,945
Legal and audit fees ...................................... 45,983
Shareholder communications expenses ....................... 36,658
Registration expenses ..................................... 32,518
Trustees' fees ............................................ 20,809
Interest expense .......................................... 17,219
Miscellaneous expenses .................................... 53,461
------------
TOTAL EXPENSES ............................................ 2,811,251
Less: Fees waived by Manager .............................. (1,898,736)
------------
TOTAL NET EXPENSES .......................................... 912,515
------------
NET INVESTMENT INCOME ....................................... 33,613,769
NET REALIZED GAIN ON INVESTMENTS ............................ 29,374
------------
NET INCREASE IN NET ASSETS RESULTING FROM OPERATIONS ........ $ 33,643,143
============
STATEMENT OF CHANGES IN NET ASSETS
================================================================================
YEAR ENDED YEAR ENDED
SEPTEMBER 30, 2006 SEPTEMBER 30, 2005
------------------ ------------------
OPERATIONS:
Net investment income .................................... $ 33,613,769 $ 19,075,675
Net realized gain on investments ......................... 29,374 148,643
--------------- ---------------
NET INCREASE IN NET ASSETS RESULTING FROM OPERATIONS ..... 33,643,143 19,224,318
--------------- ---------------
DISTRIBUTIONS TO SHAREHOLDERS:
Net investment income .................................... (33,613,769) (19,071,608)
Net realized short-term gain on investments .............. (29,374) (145,832)
--------------- ---------------
TOTAL DISTRIBUTIONS TO SHAREHOLDERS ...................... (33,643,143) (19,217,440)
--------------- ---------------
CAPITAL SHARE TRANSACTIONS ($1.00 PER SHARE):
Proceeds from shares issued .............................. 2,549,256,684 2,272,212,958
Proceeds from reinvestment of distributions .............. 33,120,607 19,013,167
Cost of shares redeemed .................................. (2,686,786,071) (2,438,662,565)
--------------- ---------------
Net decrease in net assets from capital share transactions (104,408,780) (147,436,440)
--------------- ---------------
NET DECREASE IN NET ASSETS ............................... (104,408,780) (147,429,562)
NET ASSETS:
Beginning of period ...................................... 778,298,003 925,727,565
--------------- ---------------
End of period ............................................ $ 673,889,223 $ 778,298,003
=============== ===============
See accompanying notes to financial statements.
4
THE GABELLI U.S. TREASURY MONEY MARKET FUND
NOTES TO FINANCIAL STATEMENTS
================================================================================
1. ORGANIZATION. The Gabelli U.S. Treasury Money Market Fund (the "Fund"), a
series of The Gabelli Money Market Funds (the "Trust"), was organized on May 21,
1992 as a Delaware statutory trust. The Fund is a diversified open-end
management investment company registered under the Investment Company Act of
1940, as amended (the "1940 Act"). The Fund's primary objective is high current
income consistent with the preservation of principal and liquidity. The Fund
commenced investment operations on October 1, 1992.
2. SIGNIFICANT ACCOUNTING POLICIES. The preparation of financial statements in
accordance with United States ("U.S.") generally accepted accounting principles
requires management to make estimates and assumptions that affect the reported
amounts and disclosures in the financial statements. Actual results could differ
from those estimates. The following is a summary of significant accounting
policies followed by the Fund in the preparation of its financial statements.
SECURITY VALUATION. Investments are valued at amortized cost, which approximates
market value, in accordance with Rule 2a-7 under the 1940 Act. Amortized cost
involves valuing a portfolio security at cost and any discount or premium is
amortized on a constant basis to the maturity of the instrument.
SECURITIES TRANSACTIONS AND INVESTMENT INCOME. Securities transactions are
accounted for on the trade date with realized gain or loss on investments
determined by using the identified cost method. Interest income (including
amortization of premium and accretion of discount) is recorded on the accrual
basis. Premiums and discounts on debt securities are amortized using the
constant basis or the effective yield to maturity method.
CUSTODIAN FEE CREDITS AND INTEREST EXPENSE. When cash balances are maintained in
the custody account, the Fund receives credits which are used to offset
custodian fees. The gross expenses paid under the custody arrangement are
included in custodian fees in the Statement of Operations with the corresponding
expense offset, if any, shown as "custodian fee credits." When cash balances are
overdrawn, the Fund is charged an overdraft fee of 1.00% above the Federal Funds
rate. This amount is shown as "interest expense" in the Statement of Operations.
DISTRIBUTIONS TO SHAREHOLDERS. Distributions from investment income (including
net short-term realized capital gains) are declared daily and paid monthly.
Distributions from net long-term capital gains, if any, are paid annually.
For the fiscal years ended September 30, 2006 and 2005, the tax character of
distributions is all ordinary income.
PROVISION FOR INCOME TAXES. The Fund intends to continue to qualify as a
regulated investment company under Subchapter M of the Internal Revenue Code of
1986, as amended (the "Code"). It is the policy of the Fund to comply with the
requirements of the Code applicable to regulated investment companies and to
distribute substantially all of its net investment company taxable income and
net capital gains. Therefore, no provision for Federal income taxes is required.
As of September 30, 2006, the components of accumulated earnings/(losses) on a
tax basis were as follows:
Undistributed ordinary income
(inclusive of short-term capital gains) ....... $ 404,754
Distributions payable ........................... (360,366)
Unrealized depreciation on investments .......... (44,388)
---------
Total accumulated earnings ...................... $ 0
=========
5
THE GABELLI U.S. TREASURY MONEY MARKET FUND
NOTES TO FINANCIAL STATEMENTS (CONTINUED)
================================================================================
September 30, 2006, the difference between book and tax basis undistributed
ordinary income and unrealized depreciation is primarily due to the deferral of
losses on wash sales.
Under the current tax law, capital losses related to securities realized after
October 31 and prior to the Fund's fiscal year end may be treated as occurring
on the first day of the following year. For the fiscal year ended September 30,
2006, the Fund had no capital losses to defer.
The following summarizes the tax cost of investments and the related unrealized
appreciation/depreciation at September 30, 2006:
GROSS GROSS NET UNREALIZED
UNREALIZED UNREALIZED APPRECIATION/
COST APPRECIATION DEPRECIATION (DEPRECIATION)
------------ ------------ ------------ ------------
Investments ..... $672,831,440 $ 0 $(44,388) $(44,388)
NEW ACCOUNTING PRONOUNCEMENTS. In July 2006, the Financial Accounting Standards
Board (the "FASB") issued Interpretation No. 48, "Accounting for Uncertainty in
Income Taxes, an Interpretation of FASB Statement No. 109" ("the
Interpretation"). The Interpretation establishes for all entities, including
pass-through entities such as the Fund, a minimum threshold for financial
statement recognition of the benefit of positions taken in filing tax returns
(including whether an entity is taxable in a particular jurisdiction), and
requires certain expanded tax disclosures. The Interpretation is effective for
fiscal years beginning after December 15, 2006, and is to be applied to all open
tax years as of the date of effectiveness. Management has recently begun to
evaluate the application of the Interpretation to the Fund, and is not in a
position at this time to estimate the significance of its impact, if any, on the
Fund's financial statements.
3. AGREEMENTS WITH AFFILIATED PARTIES. The Trust has entered into a management
agreement (the "Management Agreement") with Gabelli Funds, LLC (the "Manager"),
which provides that the Trust will pay the Manager a fee, computed daily and
paid monthly, at the annual rate of 0.30% of the value of the Fund's average
daily net assets. In accordance with the Management Agreement, the Manager
provides a continuous investment program for the Fund's portfolio, oversees the
administration of all aspects of the Fund's business and affairs, and pays the
compensation of all Officers and Trustees of the Fund who are affiliated persons
of the Manager. To the extent necessary, the Manager has contractually
undertaken to assume certain expenses of the Trust so that the total expenses do
not exceed 0.30% of the Fund's average daily net assets. The contractual
arrangement is renewable annually by the Manager. Pursuant to a written
agreement, the Manager has voluntarily agreed to further limit expenses to 0.08%
of the Fund's average daily net assets from December 1, 2005 through September
30, 2007. For the fiscal year ended September 30, 2006, the Manager waived
management fees of $1,898,736. At September 30, 2006, the Fund owed the Manager
$5,101 under the Management Agreement.
The Fund pays each Trustee that is not an affiliated person of the Manager or
its affiliates (as defined in the 1940 Act) an annual retainer of $3,000 plus
$500 for each Board meeting attended and they are reimbursed for any out of
pocket expenses incurred in attending meetings. All Board committee members
receive $500 per meeting. Trustees who are directors or employees of the Manager
or an affiliated company receive no compensation or expense reimbursement from
the Fund.
6
THE GABELLI U.S. TREASURY MONEY MARKET FUND
NOTES TO FINANCIAL STATEMENTS (CONTINUED)
================================================================================
4. INDEMNIFICATIONS. The Fund enters into contracts that contain a variety of
indemnifications. The Fund's maximum exposure under these arrangements is
unknown. However, the Fund has not had prior claims or losses pursuant to these
contracts and expects the risk of loss to be remote.
5. OTHER MATTERS. The Manager and/or affiliates have received subpoenas from the
Attorney General of the State of New York and the Securities and Exchange
Commission (the "SEC") requesting information on mutual fund trading practices
involving certain funds managed by the Manager. GAMCO Investors, Inc. ("GAMCO"),
the Manager's parent company, is responding to these requests for documents and
testimony. In June 2006, GAMCO began discussions with the SEC regarding a
possible resolution of their inquiry. Since these discussions are ongoing, it
cannot be determined at this time whether they will ultimately result in a
settlement of this matter. On a separate matter, in September 2005, the Manager
was informed by the staff of the SEC that the staff may recommend to the
Commission that an administrative remedy and a monetary penalty be sought from
the Manager in connection with the actions of two of seven closed-end funds
managed by the Manager relating to Section 19(a) and Rule 19a-1 of the 1940 Act.
These provisions require registered investment companies to provide written
statements to shareholders when a dividend is made from a source other than net
investment income. While the two closed-end funds sent annual statements and
provided other materials containing this information, the funds did not send
written statements to shareholders with each distribution in 2002 and 2003. The
Manager believes that all of the funds are now in compliance. The Manager
believes that these matters would have no effect on the Fund or any material
adverse effect on the Manager or its ability to manage the Fund.
- --------------------------------------------------------------------------------
2006 TAX NOTICE TO SHAREHOLDERS (Unaudited)
U.S. GOVERNMENT INCOME:
The percentage of the ordinary income dividend paid by the Fund during the
period from October 1, 2005 through September 30, 2006 which was derived from
U.S. Treasury securities was 100%. Such income is exempt from state and local
tax in all states. Due to the diversity in state and local tax law, it is
recommended that you consult your personal tax adviser as to the
applicability of the information provided to your specific situation.
- --------------------------------------------------------------------------------
7
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
================================================================================
To the Shareholders and Board of Trustees of
The Gabelli U.S. Treasury Money Market Fund
We have audited the accompanying statement of net assets of The Gabelli U.S.
Treasury Money Market Fund (the "Fund"), a series of The Gabelli Money Market
Funds as of September 30, 2006, and the related statement of operations for the
year then ended, the statements of changes in net assets for each of the two
years in the period then ended, and the financial highlights for each of the
five years in the period then ended. These financial statements and financial
highlights are the responsibility of the Fund's management. Our responsibility
is to express an opinion on these financial statements and financial highlights
based on our audits.
We conducted our audits 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 and financial highlights are free of material misstatement. We were
not engaged to perform an audit of the Fund's internal control over financial
reporting. Our audits included consideration of internal control over financial
reporting as a basis for designing audit procedures that are appropriate in the
circumstances, but not for the purpose of expressing an opinion on the
effectiveness of the Fund's internal control over financial reporting.
Accordingly, we express no such opinion. An audit also includes examining, on a
test basis, evidence supporting the amounts and disclosures in the financial
statements and financial highlights, assessing the accounting principles used
and significant estimates made by management, and evaluating the overall
financial statement presentation. Our procedures included confirmation of
securities owned as of September 30, 2006, by correspondence with the custodian
and brokers. We believe that our audits provide a reasonable basis for our
opinion.
In our opinion, the financial statements and financial highlights referred to
above present fairly, in all material respects, the financial position of The
Gabelli U.S. Treasury Money Market Fund, a series of The Gabelli Money Market
Funds, at September 30, 2006, the results of its operations for the year then
ended, the changes in its net assets for each of the two years in the period
then ended, and its financial highlights for each of the five years in the
period then ended, in conformity with U.S. generally accepted accounting
principles.
/s/ ERNST & YOUNG LLP
Philadelphia, Pennsylvania
November 7, 2006
8
THE GABELLI U.S. TREASURY MONEY MARKET FUND
ADDITIONAL FUND INFORMATION (UNAUDITED)
================================================================================
The business and affairs of the Fund are managed under the direction of the
Fund's Board of Trustees. Information pertaining to the Trustees and officers of
the Fund is set forth below. The Fund's Statement of Additional Information
includes additional information about the Fund's Trustees and is available,
without charge, upon request, by calling 800-GABELLI (800-422-3554) or by
writing to The Gabelli Money Market Funds at One Corporate Center, Rye, NY
10580-1422.
TERM OF NUMBER OF
NAME, POSITION(S) OFFICE AND FUNDS IN FUND
ADDRESS 1 LENGTH OF COMPLEX OVERSEEN PRINCIPAL OCCUPATION(S) OTHER DIRECTORSHIPS
AND AGE TIME SERVED 2 BY TRUSTEE DURING PAST FIVE YEARS HELD BY TRUSTEE 3
- ----------------- ------------- -------------- -------------------------- -----------------
INTERESTED TRUSTEES 4:
- ---------------------
MARIO J. GABELLI Since 1992 23 Chairman of the Board and Chief Executive Director of Morgan
Trustee and Officer of GAMCO Investors, Inc. and Chief Group Holdings, Inc.
Chief Investment Officer Investment Officer-Value Portfolios of (holding company)
Age: 64 Gabelli Funds, LLC and GAMCO Asset
Management Inc.; Chairman and Chief
Executive Officer of Lynch Interactive
Corporation (multimedia and services)
NON-INTERESTED TRUSTEES:
- -----------------------
ANTHONY J. COLAVITA Since 1992 33 Partner in the law firm of --
Trustee Anthony J. Colavita, P.C.
Age: 70
VINCENT D. ENRIGHT Since 1992 13 Former Senior Vice President and Chief Director of Aphton
Trustee Financial Officer of KeySpan Energy Corporation
Age: 62 Corporation (utility holding company) (biopharmaceutical
company)
ROBERT C. KOLODNY, MD Since 2006 1 Physician, author and lecturer (self- --
Trustee employed) since 1983; General Partner
Age: 62 of KBS Partnership, KBS II Investment
Partnership, KBS III Investment
Partnership, KBS IV Limited Partnership,
KBS New Dimensions, L.P., KBS Global
Opportunities, L.P. and KBS VII Limited
Partnership (private investment
partnerships) since 1981; Medical
Director and Chairman of the Board of
the Behavioral Medicine Institute since
1983
ANTHONIE C. VAN EKRIS Since 1992 17 Chairman of BALMAC International, Inc. --
Trustee (commodities and futures trading)
Age: 72
9
THE GABELLI U.S. TREASURY MONEY MARKET FUND
ADDITIONAL FUND INFORMATION (UNAUDITED) (CONTINUED)
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TERM OF
NAME, POSITION(S) OFFICE AND
ADDRESS 1 LENGTH OF PRINCIPAL OCCUPATION(S)
AND AGE TIME SERVED 2 DURING PAST FIVE YEARS
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OFFICERS:
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BRUCE N. ALPERT Since 1992 Executive Vice President and Chief Operating
President Officer of Gabelli Funds, LLC since 1988;
Age: 54 Director and President of Gabelli Advisers, Inc.
since 1998; Officer of all of the registered
investment companies in the Gabelli Funds
complex
HENLEY L. SMITH Since 1992 Senior Portfolio Manager of Gabelli Fixed Income
Vice President LLC and its predecessors since 1987
Age: 50
RONALD S. EAKER Since 1992 Senior Portfolio Manager of Gabelli Fixed Income
Vice President LLC and its predecessors since 1987
Age: 45
JUDITH RANERI Since 1997 Portfolio Manager of Gabelli Funds, LLC since April
Vice President 1997; Former Senior Portfolio Manager, Secretary and
and Portfolio Manager Treasurer of The Treasurer's Fund, Inc. and a member
Age: 38 of its Investment and Credit Review Committees
AGNES MULLADY Since 2006 Treasurer of all of the registered investment companies
Treasurer in the Gabelli Funds complex; Senior Vice President
Age: 48 of U.S. Trust Company, N.A. and Treasurer and
Chief Financial Officer of Excelsior Funds from
2004 through 2005; Chief Financial Officer of
AMIC Distribution Partners from 2002 through 2004;
Controller of Reserve Management Corporation and
Reserve Partners, Inc. and Treasurer of Reserve
Funds from 2000 through 2002
JAMES E. MCKEE Since 1995 Vice President, General Counsel and Secretary of
Secretary GAMCO Investors, Inc. since 1999 and GAMCO
Age: 43 Asset Management Inc. since 1993; Secretary of all
of the registered investment companies in the
Gabelli Funds complex
PETER D. GOLDSTEIN Since 2004 Director of Regulatory Affairs of GAMCO
Chief Compliance Officer Investors, Inc. since 2004; Chief Compliance
Age: 53 Officer of all of the registered investment
companies in the Gabelli Funds complex; Vice
President of Goldman Sachs Asset Management
(2000-2004)
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1 Address: One Corporate Center, Rye, NY 10580-1422, unless otherwise noted.
2 Each Trustee will hold office for an indefinite term until the earliest of
(i) the next meeting of shareholders, if any, called for the purpose of
considering the election or re-election of such Trustee and until the
election and qualification of his or her successor, if any, elected at such
meeting, or (ii) the date a Trustee resigns or retires, or a Trustee is
removed by the Board of Trustees or shareholders, in accordance with the
Trust's Amended and Restated By Laws and Agreement and Declaration of
Trust. Each officer will hold office for an indefinite term until the date
he or she resigns or retires or until his or her successor is elected and
qualified.
3 This column includes only directorships of companies required to report to
the SEC under the Securities Exchange Act of 1934 (i.e., public companies)
or other investment companies registered under the 1940 Act.
4 "Interested person" of the Fund as defined in the 1940 Act. Mr. Gabelli is
considered an "interested person" because of his affiliation with Gabelli
Funds, LLC which acts as the Fund's investment adviser.
10
GABELLI FAMILY OF FUNDS
VALUE _______________________________________
GABELLI ASSET FUND
Seeks to invest primarily in a diversified portfolio of common stocks selling at
significant discounts to their private market value. The Fund's primary
objective is growth of capital. (MULTICLASS)
PORTFOLIO MANAGER: MARIO J. GABELLI, CFA
GABELLI BLUE CHIP VALUE FUND
Seeks long term growth of capital through investment primarily in the common
stocks of established companies which are temporarily out of favor. The fund's
objective is to identify a catalyst or sequence of events that will return the
company to a higher value.
(MULTICLASS) PORTFOLIO MANAGER: BARBARA MARCIN, CFA
WESTWOOD EQUITY FUND
Seeks to invest primarily in the common stock of well-seasoned companies that
have recently reported positive earnings surprises and are trading below
Westwood's proprietary growth rate estimates. The Fund's primary objective is
capital appreciation.
(MULTICLASS) PORTFOLIO MANAGER: SUSAN M. BYRNE
FOCUSED VALUE _______________________________
GABELLI VALUE FUND
Seeks to invest in securities of companies believed to be undervalued. The
Fund's primary objective is long-term capital appreciation. (MULTICLASS)
PORTFOLIO MANAGER: MARIO J. GABELLI, CFA
SMALL CAP VALUE _____________________________
GABELLI SMALL CAP FUND
Seeks to invest primarily in common stock of smaller companies (market
capitalizations of $2 billion or less) believed to have rapid revenue and
earnings growth potential. The Fund's primary objective is capital appreciation.
(MULTICLASS) PORTFOLIO MANAGER: MARIO J. GABELLI, CFA
WESTWOOD SMALLCAP EQUITY FUND
Seeks to invest primarily in smaller capitalization equity securities - market
caps of $2.5 billion or less. The Fund's primary objective is long-term capital
appreciation. (MULTICLASS) TEAM MANAGED
GABELLI WOODLAND SMALL CAP VALUE FUND
Seeks to invest primarily in the common stocks of smaller companies (market
capitalizations less than $3.0 billion) believed to be undervalued with
shareholder oriented management teams that are employing strategies to grow the
company's value. The Fund's primary objective is capital appreciation.
(MULTICLASS) PORTFOLIO MANAGER: ELIZABETH M. LILLY, CFA
GROWTH ______________________________________
GAMCO GROWTH FUND
Seeks to invest primarily in large cap stocks believed to have favorable, yet
undervalued, prospects for earnings growth. The Fund's primary objective is
capital appreciation. (MULTICLASS) PORTFOLIO MANAGER: HOWARD F. WARD, CFA
GAMCO INTERNATIONAL GROWTH FUND
Seeks to invest in the equity securities of foreign issuers with long-term
capital appreciation potential. The Fund offers investors global
diversification. (MULTICLASS) PORTFOLIO MANAGER: CAESAR BRYAN
AGGRESSIVE GROWTH ___________________________
GAMCO GLOBAL GROWTH FUND
Seeks capital appreciation through a disciplined investment program focusing on
the globalization and interactivity of the world's marketplace. The Fund invests
in companies at the forefront of accelerated growth. The Fund's primary
objective is capital appreciation. (MULTICLASS) TEAM MANAGED
MICRO-CAP ___________________________________
WESTWOOD MIGHTY MITES(SM) FUND
Seeks to invest in micro-cap companies that have market capitalizations of $300
million or less. The Fund's primary objective is long-term capital appreciation.
(MULTICLASS) TEAM MANAGED
EQUITY INCOME _______________________________
GABELLI EQUITY INCOME FUND
Seeks to invest primarily in equity securities with above market average yields.
The Fund pays monthly dividends and seeks a high level of total return with an
emphasis on income. (MULTICLASS) PORTFOLIO MANAGER: MARIO J. GABELLI, CFA
WESTWOOD BALANCED FUND
Seeks to invest in a balanced and diversified portfolio of stocks and bonds. The
Fund's primary objective is both capital appreciation and current income.
(MULTICLASS) CO-PORTFOLIO MANAGERS: SUSAN M. BYRNE
MARK FREEMAN, CFA
WESTWOOD INCOME FUND
Seeks to provide a high level of current income as well as long-term capital
appreciation by investing in income producing equity and fixed income
securities. (MULTICLASS) TEAM MANAGED
SPECIALTY EQUITY ____________________________
GAMCO GLOBAL CONVERTIBLE SECURITIES FUND
Seeks to invest principally in bonds and preferred stocks which are convertible
into common stock of foreign and domestic companies. The Fund's primary
objective is total return through a combination of current income and capital
appreciation. (MULTICLASS) TEAM MANAGED
GAMCO GLOBAL OPPORTUNITY FUND
Seeks to invest in common stock of companies which have rapid growth in revenues
and earnings and potential for above average capital appreciation or are
undervalued. The Fund's primary objective is capital appreciation.
(MULTICLASS) TEAM MANAGED
SECTOR ______________________________________
GAMCO GLOBAL TELECOMMUNICATIONS FUND
Seeks to invest in telecommunications companies throughout the world - targeting
undervalued companies with strong earnings and cash flow dynamics. The Fund's
primary objective is capital appreciation. (MULTICLASS) TEAM MANAGED
GAMCO GOLD FUND
Seeks to invest in a global portfolio of equity securities of gold mining and
related companies. The Fund's objective is long-term capital appreciation.
Investment in gold stocks is considered speculative and is affected by a variety
of world-wide economic, financial, and political factors. (MULTICLASS)
PORTFOLIO MANAGER: CAESAR BRYAN
GABELLI UTILITIES FUND
Seeks to provide a high level of total return through a combination of capital
appreciation and current income. (MULTICLASS) TEAM MANAGED
MERGER AND ARBITRAGE ________________________
GABELLI ABC FUND
Seeks to invest in securities with attractive opportunities for appreciation or
investment income. The Fund's primary objective is total return in various
market conditions without excessive risk of capital loss.
(NO-LOAD) PORTFOLIO MANAGER: MARIO J. GABELLI, CFA
CONTRARIAN___________________________________
GAMCO MATHERS FUND
Seeks long-term capital appreciation in various market conditions without
excessive risk of capital loss. (CLASS AAA-NO-LOAD)
PORTFOLIO MANAGER: HENRY VAN DER EB, CFA
COMSTOCK CAPITAL VALUE FUND
Seeks capital appreciation and current income. The Fund may use either long or
short positions to achieve its objective.
(MULTICLASS) PORTFOLIO MANAGER: MARTIN WEINER, CFA
COMSTOCK STRATEGY FUND
The Fund emphasizes investments in debt securities, which maximize total return
in light of credit risk, interest rate risk, and the risk associated with the
length of maturity of debt instruments. (MULTICLASS)
PORTFOLIO MANAGER: MARTIN WEINER, CFA
FIXED INCOME ________________________________
WESTWOOD INTERMEDIATE BOND FUND
Seeks to invest in a diversified portfolio of bonds with various maturities. The
Fund's primary objective is total return.
(MULTICLASS) PORTFOLIO MANAGER: MARK FREEMAN, CFA
CASH MANAGEMENT-MONEY MARKET ________________
GABELLI U.S. TREASURY MONEY MARKET FUND
Seeks to invest exclusively in short-term U.S. Treasury securities. The Fund's
primary objective is to provide high current income consistent with the
preservation of principal and liquidity. (NO-LOAD)
PORTFOLIO MANAGER: JUDITH A. RANERI
AN INVESTMENT IN THE ABOVE MONEY MARKET FUND IS NEITHER INSURED NOR GUARANTEED
BY THE FEDERAL DEPOSIT INSURANCE CORPORATION OR ANY 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.
THE FUNDS MAY INVEST IN FOREIGN SECURITIES WHICH INVOLVE RISKS NOT ORDINARILY
ASSOCIATED WITH INVESTMENTS IN DOMESTIC ISSUES, INCLUDING CURRENCY FLUCTUATION,
ECONOMIC, AND POLITICAL RISKS.
TO RECEIVE A PROSPECTUS, CALL 800-GABELLI (422-3554). INVESTORS SHOULD CAREFULLY
CONSIDER THE INVESTMENT OBJECTIVES, RISKS, CHARGES, AND EXPENSES OF THE FUND
BEFORE INVESTING. THE PROSPECTUS CONTAINS MORE INFORMATION
ABOUT THIS AND OTHER MATTERS AND SHOULD BE READ CAREFULLY BEFORE INVESTING.
THE GABELLI U.S. TREASURY MONEY MARKET FUND
One Corporate Center
Rye, New York 10580-1422
800-GABELLI
800-422-3554
FAX: 914-921-5118
WEBSITE: WWW.GABELLI.COM
E-MAIL: INFO@GABELLI.COM
Current Yield available daily by calling
800-GABELLI after 6:00 P.M.
BOARD OF TRUSTEES
Mario J. Gabelli, CFA Robert C. Kolodny, MD
CHAIRMAN AND CHIEF PHYSICIAN, AUTHOR AND LECTURER,
EXECUTIVE OFFICER GENERAL PARTNER OF
GAMCO INVESTORS, INC. KBS PARTNERSHIP
Anthony J. Colavita Anthonie C. van Ekris
ATTORNEY-AT-LAW CHAIRMAN
ANTHONY J. COLAVITA, P.C. BALMAC INTERNATIONAL, INC.
Vincent D. Enright
FORMER SENIOR VICE PRESIDENT
AND CHIEF FINANCIAL OFFICER
KEYSPAN ENERGY CORP.
OFFICERS
Bruce N. Alpert Henley L. Smith
PRESIDENT VICE PRESIDENT
James E. McKee Peter D. Goldstein
SECRETARY CHIEF COMPLIANCE OFFICER
Agnes Mullady Ronald S. Eaker
TREASURER VICE PRESIDENT
Judith A. Raneri
VICE PRESIDENT
AND PORTFOLIO MANAGER
DISTRIBUTOR
Gabelli & Company, Inc.
CUSTODIAN, TRANSFER AGENT, AND DIVIDEND AGENT
State Street Bank and Trust Company
LEGAL COUNSEL
Willkie Farr & Gallagher LLP
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This report is submitted for the general information of the shareholders of The
Gabelli U.S. Treasury Money Market Fund. It is not authorized for distribution
to prospective investors unless preceded or accompanied by an effective
prospectus.
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GAB404Q306SR
[GRAPHIC OMITTED]
PICTURE OF MARIO GABELLI
THE
GABELLI
U.S. TREASURY
MONEY MARKET
FUND
ANNUAL REPORT
SEPTEMBER 30, 2006
ITEM 2. CODE OF ETHICS.
(a) The registrant, as of the end of the period covered by this report, has
adopted a code of ethics that applies to the registrant's principal
executive officer, principal financial officer, principal accounting
officer or controller, or persons performing similar functions,
regardless of whether these individuals are employed by the registrant
or a third party.
(c) There have been no amendments, during the period covered by this
report, to a provision of the code of ethics that applies to the
registrant's principal executive officer, principal financial officer,
principal accounting officer or controller, or persons performing
similar functions, regardless of whether these individuals are employed
by the registrant or a third party, and that relates to any element of
the code of ethics description.
(d) The registrant has not granted any waivers, including an implicit
waiver, from a provision of the code of ethics that applies to the
registrant's principal executive officer, principal financial officer,
principal accounting officer or controller, or persons performing
similar functions, regardless of whether these individuals are employed
by the registrant or a third party, that relates to one or more of the
items set forth in paragraph (b) of this item's instructions.
ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.
As of the end of the period covered by the report, the registrant's board of
directors has determined that Vincent D. Enright is qualified to serve as an
audit committee financial expert serving on its audit committee and that he is
"independent."
ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.
AUDIT FEES
(a) The aggregate fees billed for each of the last two fiscal years for
professional services rendered by the principal accountant for the
audit of the registrant's annual financial statements or services that
are normally provided by the accountant in connection with statutory
and regulatory filings or engagements for those fiscal years are
$30,800 for 2006 and $29,500 for 2005.
AUDIT-RELATED FEES
(b) The aggregate fees billed in each of the last two fiscal years for
assurance and related services by the principal accountant that are
reasonably related to the performance of the audit of the registrant's
financial statements and are not reported under paragraph (a) of this
Item are $0 for 2006 and $0 for 2005.
TAX FEES
(c) The aggregate fees billed in each of the last two fiscal years for
professional services rendered by the principal accountant for tax
compliance, tax advice, and tax planning are $3,900 for 2006 and $3,900
for 2005. Tax fees represent tax compliance services provided in
connection with the review of the Registrant's tax returns.
ALL OTHER FEES
(d) The aggregate fees billed in each of the last two fiscal years for
products and services provided by the principal accountant, other than
the services reported in paragraphs (a) through (c) of this Item are $0
for 2006 and $0 for 2005.
(e)(1) Disclose the audit committee's pre-approval policies and procedures
described in paragraph (c)(7) of Rule 2-01 of Regulation S-X.
Pre-Approval Policies and Procedures. The Audit Committee ("Committee")
of the registrant is responsible for pre-approving (i) all audit and
permissible non-audit services to be provided by the independent
auditors to the registrant and (ii) all permissible non-audit services
to be provided by the independent auditors to the Adviser, Gabelli
Funds, LLC, and any affiliate of Gabelli Funds, LLC ("Gabelli") that
provides services to the registrant (a "Covered Services Provider") if
the independent auditors' engagement related directly to the operations
and financial reporting of the registrant. The Committee may delegate
its responsibility to pre-approve any such audit and permissible
non-audit services to the Chairperson of the Committee, and the
Chairperson must report to the Committee, at its next regularly
scheduled meeting after the Chairperson's pre-approval of such
services, his or her decision(s). The Committee may also establish
detailed pre-approval policies and procedures for pre-approval of such
services in accordance with applicable laws, including the delegation
of some or all of the Committee's pre-approval responsibilities to the
other persons (other than Gabelli or the registrant's officers).
Pre-approval by the Committee of any permissible non-audit services is
not required so long as: (i) the permissible non-audit services were
not recognized by the registrant at the time of the engagement to be
non-audit services; and (ii) such services are promptly brought to the
attention of the Committee and approved by the Committee or Chairperson
prior to the completion of the audit.
(e)(2) The percentage of services described in each of paragraphs (b) through
(d) of this Item that were approved by the audit committee pursuant to
paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X are as follows:
(b) Not applicable
(c) 100%
(d) Not applicable
(f) The percentage of hours expended on the principal accountant's
engagement to audit the registrant's financial statements for the most
recent fiscal year that were attributed to work performed by persons
other than the principal accountant's full-time, permanent employees
was zero percent (0%).
(g) The aggregate non-audit fees billed by the registrant's accountant for
services rendered to the registrant, and rendered to the registrant's
investment adviser (not including any sub-adviser whose role is
primarily portfolio management and is subcontracted with or overseen by
another investment adviser), and any entity controlling, controlled by,
or under common control with the adviser that provides ongoing services
to the registrant for each of the last two fiscal years of the
registrant was $141,950 for 2006 and $3,600 for 2005.
(h) The registrant's audit committee of the board of directors has
considered whether the provision of non-audit services that were
rendered to the registrant's investment adviser (not including any
sub-adviser whose role is primarily portfolio management and is
subcontracted with or overseen by another investment adviser), and any
entity controlling, controlled by, or under common control with the
investment adviser that provides ongoing services to the registrant
that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule
2-01 of Regulation S-X is compatible with maintaining the principal
accountant's independence.
ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.
Not applicable.
ITEM 6. SCHEDULE OF INVESTMENTS.
Schedule of Investments in securities of unaffiliated issuers as of the close of
the reporting period is included as part of the report to shareholders filed
under Item 1 of this form.
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.
There have been no material changes to the procedures by which the shareholders
may recommend nominees to the registrant's board of trustees, where those
changes were implemented after the registrant last provided disclosure in
response to the requirements of Item 7(d)(2)(ii)(G) of Schedule 14A (17 CFR
240.14a-101), or this Item.
ITEM 11. CONTROLS AND PROCEDURES.
(a) The registrant's principal executive and principal financial officers,
or persons performing similar functions, have concluded that the
registrant's disclosure controls and procedures (as defined in Rule
30a-3(c) under the Investment Company Act of 1940, as amended (the
"1940 Act") (17 CFR 270.30a-3(c))) are effective, as of a date within
90 days of the filing date of the report that includes the disclosure
required by this paragraph, based on their evaluation of these controls
and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR
270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities
Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or
240.15d-15(b)).
(b) There were no changes in the registrant's internal control over
financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17
CFR 270.30a-3(d)) that occurred during the registrant's second fiscal
quarter of the period covered by this report that has materially
affected, or is reasonably likely to materially affect, the
registrant's internal control over financial reporting.
ITEM 12. EXHIBITS.
(a)(1) Code of ethics, or any amendment thereto, that is the subject of
disclosure required by Item 2 is attached hereto.
(a)(2) Certifications pursuant to Rule 30a-2(a) under the 1940 Act and
Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.
(a)(3) Not applicable.
(b) Certifications pursuant to Rule 30a-2(b) under the 1940 Act and
Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.
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) The Gabelli Money Market Funds
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By (Signature and Title)* /s/ Bruce N. Alpert
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Bruce N. Alpert, Principal Executive Officer
Date 11/27/06
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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.
By (Signature and Title)* /s/ Bruce N. Alpert
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Bruce N. Alpert, Principal Executive Officer
Date 11/27/06
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By (Signature and Title)* /s/ Agnes Mullady
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Agnes Mullady,
Principal Financial Officer and Treasurer
Date 11/27/06
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* Print the name and title of each signing officer under his or her signature.