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 811-4718
Van Kampen Tax Free Money Fund
 
(Exact name of registrant as specified in charter)
522 Fifth Avenue, New York, New York 10036
 
(Address of principal executive offices)           (Zip code)
Edward C. Wood III
522 Fifth Avenue, New York, New York 10036
 
(Name and address of agent for service)
Registrant’s telephone number, including area code: 212-762-4000
Date of fiscal year end: 6/30
Date of reporting period: 6/30/09
 
 

 


 

Item 1. Report to Shareholders.
 
The Fund’s annual report transmitted to shareholders pursuant to Rule 30e-1
under the Investment Company Act of 1940 is as follows:
ANNUAL REPORT
 
June 30, 2009
 
     
     
     
     
   
MUTUAL FUNDS

Van Kampen
Tax Free
Money Fund
     
    Privacy Notice information on the back.
     
     
     

   (VAN KAMPEN INVESTMENTS LOGO)
   
     


 

 
Welcome, Shareholder
 
In this report, you’ll learn about how your investment in Van Kampen Tax Free Money Fund performed during the annual period. The portfolio management team will provide an overview of the market conditions and discuss some of the factors that affected investment performance during the reporting period. In addition, this report includes the fund’s financial statements and a list of fund investments as of June 30, 2009.
 
 
This material must be preceded or accompanied by a prospectus for the fund being offered. The prospectus contains information about the fund, including the investment objectives, risks, charges and expenses. Please read the prospectus carefully before investing.
 
Market forecasts provided in this report may not necessarily come to pass. There is no assurance that the fund will achieve its investment objective. The fund is subject to market risk, which is the possibility that the market values of securities owned by the fund will decline and that the value of the fund shares may therefore be less than what you paid for them. Accordingly, you can lose money investing in this fund.
 
An investment in a money market fund is neither insured nor guaranteed by the Federal Deposit Insurance Corporation nor any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund.
 
             
NOT FDIC INSURED
    OFFER NO BANK GUARANTEE     MAY LOSE VALUE
NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY
    NOT A DEPOSIT
             


 

Fund Report
For the 12-month period ended June 30, 2009
 
Market Conditions
 
June 30, 2009 marked the end of most state and local governments’ fiscal years. While many issuers made mid-year budget adjustments last winter to close their budget gaps, the economy continued to contract further, creating significant shortfalls that need to be addressed by further action as most state and local governments are required by law to have balanced budgets. Tax revenues have declined sharply this year; personal income tax receipts dropped an average of 15.8 percent in the first three months of 2009, according to the Rockefeller Institute, while corporate and sales tax receipts fell 16.2 percent and 7.6 percent, respectively. Given that tax collections lag economic activity, the few reports we have to date for the month of April are also alarming. For example, New York State reported collecting $239 million less than was expected in April, while New Jersey’s fiscal year 2010 budget gap increased to $9 billion from $7 billion, based on the state’s poor April collections.
 
The extreme volatility in the financial markets and the flight to quality during the reporting year led to strong demand for money market securities. This, coupled with a constrained supply, led yields on weekly variable-rate securities to decline significantly. The SIFMA Index, the benchmark for weekly variable-rate securities, declined from a yield of 1.55 percent at the end of June 2008 to 0.35 percent on June 30, 2009.
 
Similarly, the Bond Buyer One-Year Note Index, which resets weekly, fell from 1.69 percent to 0.67 percent, although the latter yield was a 14 basis point increase from the prior month.
 
 
1


 

Performance Analysis
 
For the 12-month period ended June 30, 2009, the Fund provided a total return of 0.44 percent. For the seven-day period ended June 30, 2009, the Fund provided an annualized yield of 0.01 percent. The yield reflects the current earnings of the Fund more closely than does the total return calculation. Total return assumes reinvestment of all distributions. Past performance is no guarantee of future results.
 
Protecting the safety and liquidity of the portfolio’s assets remained our first priority. In the recent turbulent markets, our emphasis has been on managing exposure to institutions under stress. To that end, we remained focused on securities where our credit and risk teams have confidence in the quality of the issuer, the structure of the program, and the financial strength of the supporting institutions.
 
Market Outlook
 
Almost all state and local governments are required by their constitutions or charters to pass balanced budgets. Doing so this year will be difficult because expense cuts and/or revenue raisers will have to be large, which will likely be politically unpopular given the economic context. Nevertheless, budgets will probably be passed and state finances will likely improve when the economy begins to recover. In fact, if the economy recovers later this year, we believe it is possible that the financial positions of many state and local governments could improve significantly because many municipal issuers will have balanced their budgets using conservative assumptions concerning economic growth in fiscal year 2010.
 
During this period of market upheaval, we continue to diligently watch for any new developments that may impact the portfolio. We will also continue to closely monitor the implications of the slowing economy on municipal government balance sheets.
 
There is no guarantee that any sectors mentioned will continue to perform as discussed herein or that securities in such sectors will be held by the Fund in the future.
 
         
Portfolio composition as of 6/30/09 (Unaudited)
 
         
7 Day Floaters     72.3 %
         
Daily Variable Rate Securities     27.7  
         
         
 
 
Subject to change daily. Provided for informational purposes only and should not be deemed as a recommendation to buy or sell the securities mentioned or securities in the sectors shown above. All percentages are as a percentage of total investments. Securities are classified by sectors that represent broad groupings of related industries. Van Kampen is a wholly owned subsidiary of a global securities firm which is engaged in a wide range of financial services including, for example, securities trading and brokerage activities, investment banking, research and analysis, financing and financial advisory services.
 
 
2


 

For More Information About Portfolio Holdings
 
Each Van Kampen fund provides a complete schedule of portfolio holdings in its semiannual and annual reports within 60 days of the end of the fund’s second and fourth fiscal quarters. The semiannual reports and the annual reports are filed electronically with the Securities and Exchange Commission (SEC) on Form N-CSRS and Form N-CSR, respectively. Van Kampen also delivers the semiannual and annual reports to fund shareholders, and makes these reports available on its public Web site, www.vankampen.com. In addition to the semiannual and annual reports that Van Kampen delivers to shareholders and makes available through the Van Kampen public Web site, each fund files a complete schedule of portfolio holdings with the SEC for the fund’s first and third fiscal quarters on Form N-Q. Van Kampen does not deliver the reports for the first and third fiscal quarters to shareholders, nor are the reports posted to the Van Kampen public Web site. You may, however, obtain the Form N-Q filings (as well as the Form N-CSR and N-CSRS filings) by accessing the SEC’s Web site, http://www.sec.gov. You may also review and copy them at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the SEC’s Public Reference Room may be obtained by calling the SEC at (800) SEC-0330. You can also request copies of these materials, upon payment of a duplicating fee, by electronic request at the SEC’s email address (publicinfo@sec.gov) or by writing the Public Reference section of the SEC, Washington, DC 20549-0102.
 
You may obtain copies of a fund’s fiscal quarter filings by contacting Van Kampen Client Relations at (800) 847-2424.
 
 
3


 

Householding Notice
 
To reduce Fund expenses, the Fund attempts to eliminate duplicate mailings to the same address. The Fund delivers a single copy of certain shareholder documents to investors who share an address, even if the accounts are registered under different names. The Fund’s prospectuses and shareholder reports (including annual privacy notices) will be delivered to you in this manner indefinitely unless you instruct us otherwise. You can request multiple copies of these documents by either calling (800) 341-2911 or writing to Van Kampen Investor Services at P.O. Box 219286, Kansas City, MO 64121-9286. Once Investor Services has received your instructions, we will begin sending individual copies for each account within 30 days.
 
Proxy Voting Policy and Procedures and Proxy Voting Record
 
You may obtain a copy of the Fund’s Proxy Voting Policy and Procedures without charge, upon request, by calling toll free (800) 847-2424 or by visiting our Web site at www.vankampen.com. It is also available on the Securities and Exchange Commission’s Web site at http://www.sec.gov.
 
You may obtain information regarding how the Fund voted proxies relating to portfolio securities during the most recent twelve-month period ended June 30 without charge by visiting our Web site at www.vankampen.com. This information is also available on the Securities and Exchange Commission’s Web site at http://www.sec.gov.
 
 
4


 

Expense Example
 
As a shareholder of the Fund, you incur ongoing costs, including management fees; distribution and service (12b-1) fees; and other Fund expenses. This example is intended to help you understand your ongoing costs (in dollars) of investing in the Fund and to compare these costs with the ongoing costs of investing in other mutual funds.
 
The example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period 1/1/09 - 6/30/09.
 
Actual Expense
 
The first line of the table below provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested, to estimate the expenses that 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 first line under the heading entitled “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.
 
Hypothetical Example for Comparison Purposes
 
The second line of the table below provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare the ongoing cost of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of the other funds.
 
Please note that the expenses shown in the table are meant to highlight your ongoing costs only. Therefore, the second line of the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds that have transactional costs, such as sales charges (loads) or contingent deferred sales charges.
 
                         
    Beginning
  Ending
  Expenses Paid
    Account Value   Account Value   During Period *
     
    1/1/09   6/30/09   1/1/09-6/30/09
 
Actual
  $ 1,000.00     $ 1,000.06     $ 1.83  
Hypothetical
    1,000.00       1,022.95       1.86  
(5% annual return before expenses)
                       
                         
                         
 
* Expenses are equal to the Fund’s annualized expense ratio of 0.37% multiplied by the average account value over the period, multiplied by 181/365 (to reflect the one-half year period). This expense ratio reflects an expense waiver.
 
Assumes all dividends and distributions were reinvested.
 
 
5


 

Investment Advisory Agreement Approval
 
Both the Investment Company Act of 1940 and the terms of the Fund’s investment advisory agreement require that the investment advisory agreement between the Fund and its investment adviser be approved annually both by a majority of the Board of Trustees and by a majority of the independent trustees voting separately.
 
At meetings held on April 17, 2009 and May 20-21, 2009, the Board of Trustees, and the independent trustees voting separately, considered and ultimately determined that the terms of the investment advisory agreement are fair and reasonable and approved the continuance of the investment advisory agreement as being in the best interests of the Fund and its shareholders. In making its determination, the Board of Trustees considered materials that were specifically prepared by the investment adviser at the request of the Board and Fund counsel, and by an independent provider of investment company data contracted to assist the Board, relating to the investment advisory agreement review process. The Board also considered information received periodically about the portfolio, performance, the investment strategy, portfolio management team and fees and expenses of the Fund. The Board of Trustees considered the investment advisory agreement over a period of several months and the trustees held sessions both with the investment adviser and separate from the investment adviser in reviewing and considering the investment advisory agreement.
 
In approving the investment advisory agreement, the Board of Trustees considered, among other things, the nature, extent and quality of the services provided by the investment adviser, the performance, fees and expenses of the Fund compared to other similar funds and other products, the investment adviser’s expenses in providing the services and the profitability of the investment adviser and its affiliated companies. The Board of Trustees considered the extent to which any economies of scale experienced by the investment adviser are shared with the Fund’s shareholders, and the propriety of existing and alternative breakpoints in the Fund’s investment advisory fee schedule. The Board of Trustees considered comparative advisory fees of the Fund and other investment companies and/or other products at different asset levels, and considered the trends in the industry versus historical and projected assets of the Fund. The Board of Trustees evaluated other benefits the investment adviser and its affiliates derive from their relationship with the Fund. The Board of Trustees reviewed information about the foregoing factors and considered changes, if any, in such information since its previous approval. The Board of Trustees discussed the financial strength of the investment adviser and its affiliated companies and the capability of the personnel of the investment adviser, and specifically the strength and background of its portfolio management personnel. The Board of Trustees reviewed the statutory and regulatory requirements for approval and disclosure of investment advisory agreements. The Board of Trustees, including the independent trustees, evaluated all of the foregoing and does not believe any single factor or group of factors control or dominate the review process, and,
 
 
6


 

after considering all factors together, has determined, in the exercise of its business judgment, that approval of the investment advisory agreement is in the best interests of the Fund and its shareholders. The following summary provides more detail on certain matters considered but does not detail all matters considered.
 
Nature, Extent and Quality of the Services Provided. On a regular basis, the Board of Trustees considers the roles and responsibilities of the investment adviser as a whole and those specific to portfolio management, support and trading functions servicing the Fund. The trustees discuss with the investment adviser the resources available and used in managing the Fund. The trustees also discuss certain other services which are provided on a cost-reimbursement basis by the investment adviser or its affiliates to the Van Kampen funds including certain accounting, administrative and legal services. The Board has determined that the nature, extent and quality of the services provided by the investment adviser support its decision to approve the investment advisory agreement.
 
Performance, Fees and Expenses of the Fund. On a regular basis, the Board of Trustees reviews the performance, fees and expenses of the Fund compared to its peers and to appropriate benchmarks. In addition, the Board spends more focused time on the performance of the Fund and other funds in the Van Kampen complex, paying specific attention to underperforming funds. The trustees discuss with the investment adviser the performance goals and the actual results achieved in managing the Fund. When considering a fund’s performance, the trustees and the investment adviser place emphasis on trends and longer-term returns (focusing on one-year, three-year and five-year performance with special attention to three-year performance) and, when a fund’s weighted performance is under the fund’s benchmark or peers, they discuss the causes and where necessary seek to make specific changes to investment strategy or investment personnel. The Fund discloses more information about its performance elsewhere in this report and in the Fund’s prospectus. The trustees discuss with the investment adviser the level of advisory fees for this Fund relative to comparable funds and other products advised by the adviser and others in the marketplace. The trustees review not only the advisory fees but other fees and expenses (whether paid to the adviser, its affiliates or others) and the Fund’s overall expense ratio. The Fund discloses more information about its fees and expenses in its prospectus. The Board has determined that the performance, fees and expenses of the Fund support its decision to approve the investment advisory agreement.
 
Investment Adviser’s Expenses in Providing the Service and Profitability. At least annually, the trustees review the investment adviser’s expenses in providing services to the Fund and other funds advised by the investment adviser and the profitability of the investment adviser. These profitability reports are put together by the investment adviser with the oversight of the Board. The trustees discuss with the investment adviser its revenues and expenses, including, among other things, revenues for advisory services, portfolio management-related expenses,
 
 
7


 

revenue sharing arrangement costs and allocated expenses both on an aggregate basis and per fund. The Board has determined that the analysis of the investment adviser’s expenses and profitability support its decision to approve the investment advisory agreement.
 
Economies of Scale. On a regular basis, the Board of Trustees considers the size and growth prospects of the Fund and how that relates to the Fund’s expense ratio and particularly the Fund’s advisory fee rate. In conjunction with its review of the investment adviser’s profitability, the trustees discuss with the investment adviser how more (or less) assets can affect the efficiency or effectiveness of managing the Fund’s portfolio and whether the advisory fee level is appropriate relative to current and projected asset levels and/or whether the advisory fee structure reflects economies of scale as asset levels change. The Board has determined that its review of the actual and potential economies of scale of the Fund support its decision to approve the investment advisory agreement.
 
Other Benefits of the Relationship. On a regular basis, the Board of Trustees considers other benefits to the investment adviser and its affiliates derived from the investment adviser’s relationship with the Fund and other funds advised by the investment adviser. These benefits include, among other things, fees for transfer agency services provided to the funds, in certain cases research received by the adviser generated from commission dollars spent on funds’ portfolio trading, and in certain cases distribution or service related fees related to funds’ sales. The trustees review with the investment adviser each of these arrangements and the reasonableness of its costs relative to the services performed. The Board has determined that the other benefits received by the investment adviser or its affiliates support its decision to approve the investment advisory agreement.
 
 
8


 

Van Kampen Tax Free Money Fund
Portfolio of Investments   n   June 30, 2009
 
                             
Par
          Current
   
Amount
      Maturity
  Yield at
  Amortized
(000)   Description   Date *   6-30-09   Cost
 
 
        Municipal Bonds  100.1%
7 Day Floaters  72.4%
$ 600     Broward Cnty, FL Ed Fac Auth City Coll Proj (LOC: Citibank)   07/02/09     0.300 %   $ 600,000  
  1,300     California Statewide Cmnty Dev Auth Rev Kaiser Permanente Ser B   07/01/09     0.200       1,300,000  
  1,300     Cary, NC Pub Impt   07/01/09     0.230       1,300,000  
  700     Clarksville, TN Muni Pub Bldg Auth Rev Pooled Fin TN Bd Fd (LOC: Bank of America) (Acquired 10/10/08, Cost $700,000) (a)   07/02/09     0.320       700,000  
  600     Colorado Hsg & Fin Auth Single Fam Mtg Ser B-3   07/01/09     0.350       600,000  
  685     Derry Twp, PA Indl & Coml Dev Auth Hotel Tax Rev Arena Proj (LOC: PNC Bank)   07/02/09     0.300       685,000  
  1,000     Eastern Muni Wtr Dist CA Wtr & Swr Rev Ctf Partner Ser B   07/01/09     0.160       1,000,000  
  900     Gwinnett Cnty, GA Wtr & Sew Auth Rev Ser A   07/01/09     0.320       900,000  
  700     Kent Hosp Fin Auth MI Rev Metro Hosp Proj Rfdg Ser B (LOC: Bank of America)   07/02/09     0.250       700,000  
  695     Metropolitan Govt Nashville & Davidson Cnty, TN H&E Fac Brd Rev Vanderbilt Univ Ser A   07/02/09     0.300       695,000  
  500     Michigan St Hosp Fin Auth Rev McLaren Hlthcare Rfdg Ser B (LOC: JP Morgan Chase Bank)   07/01/09     0.210       500,000  
  1,390     Minneapolis, MN Rev Univ Gateway Proj   07/02/09     0.270       1,390,000  
  1,200     Minnesota St Higher Ed Fac Auth Rev Macalester College Ser 5-Q   07/02/09     0.290       1,200,000  
  500     New Hampshire Higher Ed & Hlth Fac Auth Rev Saint Pauls Sch Issue   07/02/09     0.280       500,000  
  400     New York St Dorm Auth Rev Mental Hlth Svc Subser D-2H   07/02/09     0.250       400,000  
  500     New York St Loc Gov Assistance Corp Ser D (LOC: Societe Generale)   07/01/09     0.170       500,000  
  900     North Carolina Ed Fac Fin Agy Rev Duke Univ Proj Ser B   07/02/09     0.170       900,000  
  925     North Carolina Med Care Comm Hlth Sys Rev Mission Saint Josephs Rfdg   07/02/09     0.320       925,000  
  830     North Miami, FL Ed Fac Rev Miami Ctry Day Sch Proj (LOC: Bank of America)   07/02/09     0.340       830,000  
  675     Palm Beach Cnty, FL Rev Henry Morrison Flagler Proj (LOC: Northern Trust)   07/02/09     0.520       675,000  
  800     Pennsylvania St Tpk Comm Rev Ser A-2   07/01/09     0.400       800,000  
  615     Portland, OR Hsg Auth Rev New Mkt West Proj (LOC: Wells Fargo Bank)   07/02/09     0.270       615,000  
  600     Private Colleges & Univ Auth GA Rev Emory Univ Ser B-2   07/02/09     0.120       600,000  
  1,000     San Bernadino Cnty, CA Ctf Partner Cap Impt Refing Proj (LOC: BNP Paribas)   07/02/09     0.170       1,000,000  
 
 
9
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Portfolio of Investments   n   June 30, 2009  
continued
 
                             
Par
          Current
   
Amount
      Maturity
  Yield at
  Amortized
(000)   Description   Date *   6-30-09   Cost
 
 
        7 Day Floaters (Continued)
$ 1,100     Triunfo, CA Cnty Santn Dist Rev Rfdg (LOC: BNP Paribas)   07/01/09     0.250 %   $ 1,100,000  
  200     University of Texas Univ Rev Fin Sys Rfdg Ser A   07/01/09     0.170       200,000  
  500     Utah Cnty, UT Hosp Rev IHC Hlth Svc Inc Ser B   07/02/09     0.200       500,000  
  600     Washington St Hsg Fin Comm Multi-Family Mtg Rev (LOC: Harris Trust & Savings Bank)   07/07/09     0.300       600,000  
                             
Total 7 Day Floaters  72.4%
    21,715,000  
         
         
        Daily Variable Rate Securities  27.7%
  500     Chicago, IL Rfdg Ser F   07/01/09     0.180       500,000  
  500     Chicago, IL Sales Tax Rev Rfdg   07/01/09     0.180       500,000  
  1,100     Colorado Ed & Cultural Fac Natl Jewish Fedn, Ser F-1 (LOC: Northern Trust)   07/01/09     0.230       1,100,000  
  405     Cuyahoga Cnty, OH Rev Cleveland Clinic Subser B–1   07/01/09     0.180       405,000  
  630     Dade Cnty, FL Indl Dev Auth Exempt Fac Rev FL Pwr & Lt Co Rfdg   07/01/09     0.350       630,000  
  750     Jackson Cnty, MS Pollutn Ctl Refing Chevron USA Inc Proj   07/01/09     0.220       750,000  
  600     Jacksonville, FL Pollutn Rev Ctl FL Pwr & Lt Co Proj Rfdg   07/01/09     0.720       600,000  
  870     Kentucky Inc KY Pub Energy Auth Gas Supply Rev Ser A   07/01/09     0.300       870,000  
  300     Long Island Pwr Auth NY Elec Sys Rev Ser 2B (LOC: Bayerische Landesbank)   07/01/09     0.350       300,000  
  700     Pitkin Cnty, CO Indl Dev Rev Aspen Skiing Co Proj Rfdg Ser A (LOC: JP Morgan Chase Bank)   07/01/09     0.230       700,000  
  1,100     Southeast, AL Gas Dist Rev Supply Proj Ser A   07/01/09     0.300       1,100,000  
  350     University of Michigan Rev Hosp Ser A   07/01/09     0.180       350,000  
  500     University of NC Hosp Chapel Hill Rev Ser B   07/01/09     0.320       500,000  
                             
         
Total Daily Variable Rate Securities  27.7%
    8,305,000  
         
         
Total Investments  100.1% (b) (c)
    30,020,000  
         
Liabilities in Excess of Other Assets  (0.1%)
    (32,745 )
         
         
Net Assets  100.0%
  $ 29,987,255  
         
 
 
Percentages are calculated as a percentage of net assets.
 
* Date of next interest rate reset.
 
 
10
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Portfolio of Investments   n   June 30, 2009  
continued
 
 
(a) Security is restricted and may be resold only in transactions exempt from registration which are normally those transactions with qualified institutional buyers. Restricted securities comprise 2.3% of net assets.
 
(b) Securities include a put feature allowing the Fund to periodically put the security back to the issuer at amortized cost on specified dates. The yield shown represents the current yield earned by the Fund based on the most recent reset date. The maturity date shown represents the next put date.
 
(c) At June 30, 2009, cost is identical for both book and federal income tax purposes.
 
LOC—Letter of Credit
 
Fair Value Measurements
 
Various inputs are used in determining the value of the Fund’s investments. These inputs are summarized in the three broad levels listed below. (See Note 1(B) to the financial statements for further information regarding fair value measurements.)
 
The following is a summary of the inputs used as of June 30, 2009 in valuing the Fund’s investments carried at value:
 
         
    Short-Term
Valuation Inputs   Municipal Bonds
 
Level 1—Quoted Prices
  $ -0-  
Level 2—Other Significant Observable Inputs
    30,020,000  
Level 3—Significant Unobservable Inputs
    -0-  
         
Total
  $ 30,020,000  
         
 
 
11
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Financial Statements
 
Statement of Assets and Liabilities
June 30, 2009
 
             
Assets:
           
Total Investments, at amortized cost which approximates market value
  $ 30,020,000      
Cash
    10,938      
Receivables:
           
Investments Sold
    100,000      
Fund Shares Sold
    14,894      
Interest
    7,550      
Expense Reimbursement from Adviser
    7,502      
Other
    97,996      
             
Total Assets
    30,258,880      
             
Liabilities:
           
Payables:
           
Fund Shares Repurchased
    30,674      
Distributor and Affiliates
    11,867      
Trustees’ Deferred Compensation and Retirement Plans
    173,121      
Accrued Expenses
    55,963      
             
Total Liabilities
    271,625      
             
Net Assets
  $ 29,987,255      
             
Net Assets Consist of:
           
Capital (Par value of $.01 per share with an unlimited number of shares authorized)
  $ 30,132,720      
Accumulated Net Realized Loss
    (18,652 )    
Accumulated Undistributed Net Investment Income
    (126,813 )    
             
Net Assets (Equivalent to $1.00 per share for 30,010,260 shares outstanding)
  $ 29,987,255      
             
 
 
12
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Financial Statements  
continued
 
Statement of Operations
For the Year Ended June 30, 2009
 
             
Investment Income:
           
Interest
  $ 354,666      
             
Expenses:
           
Investment Advisory Fee
    153,696      
Distribution (12b-1) and Service Fees
    85,386      
Professional Fees
    59,255      
Transfer Agent Fees
    38,172      
Registration Fees
    35,944      
Reports to Shareholders
    31,610      
Trustees’ Fees and Related Expenses
    19,046      
Accounting and Administrative Expenses
    14,104      
Custody
    9,122      
Other
    28,973      
             
Total Expenses
    475,308      
Expense Reduction
    250,259      
             
Net Expenses
    225,049      
             
Net Investment Income
  $ 129,617      
             
Net Increase in Net Assets From Operations
  $ 129,617      
             
 
 
13
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Financial Statements  
continued
 
Statements of Changes in Net Assets
 
                 
    For The
  For The
    Year Ended
  Year Ended
    June 30, 2009   June 30, 2008
     
 
From Investment Activities:
               
Operations:
               
Net Investment Income
  $ 129,617     $ 310,909  
                 
Change in Net Assets from Operations
    129,617       310,909  
Distributions from Net Investment Income
    (125,071 )     (305,599 )
                 
                 
Net Change in Net Assets from Investment Activities
    4,546       5,310  
                 
                 
From Capital Transactions:
               
Proceeds from Shares Sold
    68,242,780       38,791,122  
Net Asset Value of Shares Issued Through Dividend Reinvestment
    125,071       305,599  
Cost of Shares Repurchased
    (58,727,216 )     (33,415,758 )
                 
                 
Net Change in Net Assets from Capital Transactions
    9,640,635       5,680,963  
                 
Total Increase in Net Assets
    9,645,181       5,686,273  
Net Assets:
               
Beginning of the Period
    20,342,074       14,655,801  
                 
End of the Period (Including accumulated undistributed net investment income of $(126,813) and $(4,546), respectively)
  $ 29,987,255     $ 20,342,074  
                 
 
 
14
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Financial Highlights
 
The following schedule presents financial highlights for one share of the Fund outstanding throughout the periods indicated.
 
                                         
    Year Ended June 30,
    2009   2008   2007   2006   2005
     
 
Net Asset Value, Beginning of the Period
  $ 1.00     $ 1.00     $ 1.00     $ 1.00     $ 1.00  
                                         
Net Investment Income
    0.00  (a)(b)     0.02 (a)     0.02 (a)     0.02 (a)     0.01  
Net Realized and Unrealized Gain
    -0-       -0-       -0- (b)     -0-       0.00  
                                         
Total from Investment Operations
    0.00 (b)     0.02       0.02       0.02       0.01  
Less Distributions from Net Investment Income
    0.00 (b)     0.02       0.02       0.02       0.01  
                                         
Net Asset Value, End of the Period
  $ 1.00     $ 1.00     $ 1.00     $ 1.00     $ 1.00  
                                         
                                         
Total Return *  (c)
    0.44% (e)     1.51%       2.07%       1.53%       0.73%  
Net Assets at End of the Period (In millions)
  $ 30.0     $ 20.3     $ 14.7     $ 16.1     $ 17.5  
Ratio of Expenses to Average Net Assets *  (d)
    0.66% (e)     1.26%       1.57%       1.43%       1.18%  
Ratio of Net Investment Income to Average Net Assets *
    0.38% (e)     1.51%       2.09%       1.54%       0.58%  
*  If certain expenses had not been voluntarily assumed by Van Kampen, total return would have been lower and the ratios would have been as follows:
Ratio of Expenses to Average Net Assets  (d)
    1.39% (e)     2.22%       2.22%       1.92%       1.73%  
Ratio of Net Investment Income/Loss to Average Net Assets
    (0.35% ) (e)     0.55%       1.44%       1.05%       0.03%  
 
(a) Based on average shares outstanding.
 
(b) Amount is less than $0.01 per share.
 
(c) Assumes reinvestment of all distributions for the period and includes combined Rule 12b-1 fees and service fees of up to .25%.
 
(d) The Ratio of Expenses to Average Net Assets does not reflect credits earned on cash balances. If these credits were reflected as a reduction of expenses, the ratio would decrease by 0.02% for the year ended June 30, 2007.
 
(e) The Total Return, Ratio of Expenses to Average Net Assets and Ratio of Net Investment Income/Loss to Average Net Assets reflect actual 12b-1 fees of less than .25% (See footnote 4).
 
 
15
See Notes to Financial Statements


 

Van Kampen Tax Free Money Fund
Notes to Financial Statements   n   June 30, 2009
 
1. Significant Accounting Policies
Van Kampen Tax Free Money Fund (the “Fund”) is organized as a Delaware statutory trust. The Fund is an open-end, diversified management investment company registered under the Investment Company Act of 1940, as amended (the “1940 Act”). The Fund’s investment objective is to seek to provide investors with a high level of current income exempt from federal income taxes consistent with the preservation of capital and liquidity through investments in a diversified portfolio of municipal securities that will mature within twelve months of the date of purchase. The Fund commenced investment operations on November 5, 1986.
The following is a summary of significant accounting policies consistently followed by the Fund in the preparation of its financial statements. The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.
 
A. Security Valuation  Investments are valued at amortized cost, which approximates market value. Under this valuation method, a portfolio investment is valued at cost, any discount is accreted and any premium is amortized on a straight-line basis to the maturity of the instrument.
 
B. Fair Value Measurements  Financial Accounting Standards Board Statement of Financial Accounting Standards No. 157, Fair Value Measurements (FAS 157), defines fair value as the price that the Fund would receive to sell an investment or pay to transfer a liability in an orderly transaction with an independent buyer in the principal market, or in the absence of a principal market the most advantageous market for the investment or liability. FAS 157 establishes a three-tier hierarchy to distinguish between (1) inputs that reflect the assumptions market participants would use in pricing an asset or liability developed based on market data obtained from sources independent of the reporting entity (observable inputs) and (2) inputs that reflect the reporting entity’s own assumptions about the assumptions market participants would use in pricing an asset or liability developed based on the best information available in the circumstances (unobservable inputs) and to establish classification of fair value measurements for disclosure purposes. Various inputs are used in determining the value of the Fund’s investments. The inputs are summarized in the three broad levels listed below.
 
Level 1— quoted prices in active markets for identical investments
Level 2— other significant observable inputs (including quoted prices for similar investments, interest rates, prepayment speeds, credit risk, etc.)
Level 3— significant unobservable inputs (including the Fund’s own assumptions in determining the fair value of investments)
 
The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.
 
 
16


 

Van Kampen Tax Free Money Fund
Notes to Financial Statements  
n   June 30, 2009   continued
 
C. Security Transactions  Security transactions are recorded on a trade date basis. Realized gains and losses are determined on an identified cost basis. Interest income is recorded on an accrual basis.
 
D. Federal Income Taxes  It is the Fund’s policy to comply with the requirements of Subchapter M of the Internal Revenue Code applicable to regulated investment companies and to distribute substantially all of its taxable income, if any, to its shareholders. Therefore, no provision for federal income taxes is required. Financial Accounting Standards Board Interpretation No. 48, Accounting for Uncertainty in Income Taxes , sets forth a minimum threshold for financial statement recognition of the benefit of a tax position taken or expected to be taken in a tax return. Management has concluded there are no significant uncertain tax positions that would require recognition in the financial statements. If applicable, the Fund recognizes interest accrued related to unrecognized tax benefits in “Interest Expense” and penalties in “Other” expenses on the Statement of Operations. The Fund files tax returns with the U.S. Internal Revenue Service. Generally, each of the tax years in the four year period ended June 30, 2009, remains subject to examination by taxing authorities.
The Fund intends to utilize provisions of the federal income tax laws, which allow it to carry a realized capital loss forward for eight years following the year of the loss and offset such losses against any future realized capital gains. At June 30, 2009, the Fund had an accumulated capital loss carry forward for tax purposes of $14,956, which will expire according to the following schedule:
 
                 
Amount       Expiration
 
$ 4,652           June 30, 2012  
  101           June 30, 2013  
  10,203           June 30, 2017  
 
E. Distribution of Income and Gains  The Fund declares dividends from net investment income daily and automatically reinvests such dividends daily. Net realized gains, if any, are distributed at least annually. Shareholders can elect to receive the cash equivalent of their daily dividends at each month end.
The tax character of distributions paid during the years ended June 30, 2009 and 2008 was as follows:
 
                 
    2009   2008
 
Distributions paid from:
               
Ordinary income
  $ 1,524     $ 1,754  
Tax-exempt income
    264,817       309,348  
                 
    $ 266,341     $ 311,102  
                 
 
Permanent differences, primarily due to the utilization of earnings and profits distributed to the shareholders on redemption of shares as part of the dividends paid deduction for
 
 
17


 

Van Kampen Tax Free Money Fund
Notes to Financial Statements  
n   June 30, 2009   continued
 
income tax purposes and a deferred compensation plan reclass, resulted in the following reclassifications among the Fund’s components of net assets at June 30, 2009:
 
                     
Accumulated Undistributed Net
  Accumulated
   
Investment Income   Net Realized Loss   Capital
 
$ (126,813 )   $ (13,899 )   $ 140,712  
 
As of June 30, 2009, the components of distributable earnings on a tax basis were as follows:
 
         
Undistributed tax-exempt income
  $ 82,277  
 
F. Reporting Subsequent Events  In accordance with the provisions set forth in Financial Accounting Standards Board Statement of Financial Accounting Standards No. 165, Subsequent Events , adopted by the Fund as of June 30, 2009, management has evaluated the possibility of subsequent events existing in the Fund’s financial statements through August 21, 2009. Management has determined that there are no material events or transactions that would effect the financial statements or would require disclosure in the Fund’s financial statements through this date.
 
2. Investment Advisory Agreement and Other Transactions with Affiliates
Under the terms of the Fund’s Investment Advisory Agreement, Van Kampen Asset Management (the “Adviser”) will provide investment advice and facilities to the Fund for an annual fee payable monthly as follows:
 
         
Average Daily Net Assets   % Per Annum
 
First $500 million
    .450%  
Next $250 million
    .375%  
Next $250 million
    .325%  
Next $500 million
    .300%  
Next $500 million
    .275%  
Next $500 million
    .250%  
Next $500 million
    .225%  
Next $12 billion
    .200%  
Over $15 billion
    .199%  
 
The Fund’s Adviser is currently waiving or reimbursing all or a portion of the Fund’s advisory fees or other expenses. This resulted in a net expense ratio of .66%. The fee waivers or expense reimbursements are voluntary and can be discontinued at any time. For the year ended June 30, 2009, the Adviser waived or reimbursed approximately $197,700 of advisory fees or other expenses.
For the year ended June 30, 2009, the Fund recognized expenses of approximately $6,800 representing legal services provided by Skadden, Arps, Slate, Meagher & Flom LLP, of which a trustee of the Fund is a partner of such firm and he and his law firm provide legal services as legal counsel to the Fund.
Under separate Legal Services, Accounting Services and Chief Compliance Officer (CCO) Employment agreements, the Adviser provides accounting and legal services and the CCO
 
 
18


 

Van Kampen Tax Free Money Fund
Notes to Financial Statements  
n   June 30, 2009   continued
 
provides compliance services to the Fund. The costs of these services are allocated to each fund. For the year ended June 30, 2009, the Fund recognized expenses of approximately $24,500 representing Van Kampen Investments Inc.’s or its affiliates’ (collectively “Van Kampen”) cost of providing accounting and legal services to the Fund, as well as the salary, benefits and related costs of the CCO and related support staff paid by Van Kampen. Services provided pursuant to the Legal Services agreement are reported as part of “Professional Fees” on the Statement of Operations. Services provided pursuant to the Accounting Services and CCO Employment agreement are reported as part of “Accounting and Administrative Expenses” on the Statement of Operations.
Van Kampen Investor Services Inc. (VKIS), an affiliate of the Adviser, serves as the shareholder servicing agent for the Fund. For the year ended June 30, 2009, the Fund recognized expenses of approximately $14,300 representing transfer agency fees paid to VKIS and its affiliates. Transfer agency fees are determined through negotiations with the Fund’s Board of Trustees.
Certain officers and trustees of the Fund are also officers and directors of Van Kampen. The Fund does not compensate its officers or trustees who are also officers of Van Kampen.
The Fund provides deferred compensation and retirement plans for its trustees who are not officers of Van Kampen. Under the deferred compensation plan, trustees may elect to defer all or a portion of their compensation. Amounts deferred are retained by the Fund and, to the extent permitted by the 1940 Act, may be invested in the common shares of those funds selected by the trustees. Investments in such funds of approximately $96,200 are included in “Other” assets on the Statement of Assets and Liabilities at June 30, 2009. Appreciation/depreciation and distributions received from these investments are recorded with an offsetting increase/decrease in the deferred compensation obligation and do not affect the net asset value of the Fund. Benefits under the retirement plan are payable upon retirement for a ten-year period and are based upon each trustee’s years of service to the Fund. The maximum annual benefit per trustee under the plan is $2,500.
 
3. Capital Transactions
For the years ended June 30, 2009 and 2008, transactions were as follows:
 
                 
    Year Ended
  Year Ended
    June 30, 2009   June 30, 2008
 
Beginning Shares
    20,369,625       14,688,662  
                 
Shares Sold
    68,242,780       38,791,122  
Shares Issued Through Dividend Reinvestment
    125,071       305,599  
Shares Repurchased
    (58,727,216 )     (33,415,758 )
                 
Net Change in Shares Outstanding
    9,640,635       5,680,963  
                 
Ending Shares
    30,010,260       20,369,625  
                 
 
4. Distribution and Service Plans
Shares of the Fund are distributed by Van Kampen Funds Inc. (the “Distributor”), an affiliate of the Adviser. The Fund has adopted a distribution plan pursuant to Rule 12b-1 under the 1940 Act, and a service plan (collectively, the “Plans”) to compensate the Distributor for the sale, distribution, shareholder servicing and maintenance of shareholder accounts. Under the Plans, the Fund will incur annual fees of up to .25% of average daily net assets. These fees are
 
 
19


 

Van Kampen Tax Free Money Fund
Notes to Financial Statements  
n   June 30, 2009   continued
 
accrued daily and paid to the Distributor monthly. The Distributor is currently waiving a portion of the distribution and service fees. For the year ended June 30, 2009, the Distributor waived $52,580 of distribution and service fees. Due to the voluntary waiver, the aggregate distribution and service fees are .10%. This waiver is voluntary in nature and can be discontinued at any time.
 
5. 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.
 
6. U.S. Treasury Temporary Guaranty Program
The Board of Trustees approved the participation by the Fund in the U.S. Department of the Treasury’s Temporary Guarantee Program (“Program”) for money market funds. Although the Fund has continued to maintain a net asset value of $1.00 per share, the Fund believes that participation in the Program will provide an added level of assurance for its shareholders. The Program provides a guarantee to participating money market mutual fund shareholders based on the number of shares invested in the Fund at the close of business on September 19, 2008. Any increase in the number of shares an investor holds after the close of business on September 19, 2008, will not be guaranteed. If a customer closes his/her account with the Fund or broker-dealer, any future investment in the Fund will not be guaranteed. If the number of shares an investor holds fluctuates over the period, the investor will be covered for either the number of shares held as of the close of business on September 19, 2008, or the current amount, whichever is less. The Program had originally been set to expire on December 18, 2008, but was recently extended by the Treasury Department until September 18, 2009. The cost related to the Program, amounting to $8,634, is borne by the Fund and amortized on a straight line basis over the term of the Program’s coverage.
 
 
 
20


 

Van Kampen Tax Free Money Fund
Report of Independent Registered Public Accounting Firm
 
To the Shareholders and Board of Trustees of Van Kampen Tax Free Money Fund
 
We have audited the accompanying statement of assets and liabilities, including the portfolio of investments, of Van Kampen Tax Free Money Fund (the Fund) as of June 30, 2009, 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 June 30, 2009, by correspondence with the custodian. 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 Van Kampen Tax Free Money Fund at June 30, 2009, 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 the 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
Chicago, Illinois
August 21, 2009
 
 
21


 

Van Kampen Tax Free Money Fund
Board of Trustees, Officers and Important Addresses
 
     
Board of Trustees
David C. Arch
Jerry D. Choate
Rod Dammeyer
Linda Hutton Heagy
R. Craig Kennedy
Howard J Kerr
Jack E. Nelson
Hugo F. Sonnenschein
Wayne W. Whalen*
 – Chairman
Suzanne H. Woolsey
 
Officers
Edward C. Wood III
President and Principal Executive Officer
Kevin Klingert
Vice President
Stefanie V. Chang Yu
Vice President and Secretary
John L. Sullivan
Chief Compliance Officer
Stuart N. Schuldt
Chief Financial Officer and Treasurer
  Investment Adviser
Van Kampen Asset Management
522 Fifth Avenue
New York, New York 10036

Distributor
Van Kampen Funds Inc.
522 Fifth Avenue
New York, New York 10036

Shareholder Servicing Agent
Van Kampen Investor Services Inc.
P.O. Box 219286
Kansas City, Missouri 64121-9286

Custodian
State Street Bank
and Trust Company
One Lincoln Street
Boston, Massachusetts 02111

Legal Counsel
Skadden, Arps, Slate,
Meagher & Flom LLP
155 North Wacker Drive
Chicago, Illinois 60606

Independent Registered
Public Accounting Firm
Ernst & Young LLP
233 South Wacker Drive
Chicago, Illinois 60606
 
 
For federal income tax purposes, the following information is furnished with respect to the distributions paid by the Fund during its taxable year ended June 30, 2009. The Fund designated 99.4% of the income distributions as a tax-exempt income distribution. In addition, Fund shareholders redeemed $58,721,084 of shares during the fiscal year. Of these proceeds, $141,598 represents tax-exempt income from the Fund. In January, the Fund provides tax information to shareholders for the preceding calendar year.
 
 
* “Interested persons” of the Fund, as defined in the Investment Company Act of 1940, as amended.
 
 
22


 

Van Kampen Tax Free Money Fund
 
 
The business and affairs of each Fund are managed under the direction of the Funds’ Board of Trustees and the Funds’ officers appointed by the Board of Trustees. The tables below list the trustees and executive officers of each Fund and their principal occupations during the last five years, other directorships held by trustees and their affiliations, if any, with Van Kampen Investments, the Adviser, the Distributor, Van Kampen Advisors Inc., Van Kampen Exchange Corp. and Investor Services. The term “Fund Complex” includes each of the investment companies advised by the Adviser as of the date of this Annual Report. Trustees serve until reaching their retirement age or until their successors are duly elected and qualified. Officers are annually elected by the trustees.
 
                         
Independent Trustees
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   each Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
David C. Arch (64)
Blistex Inc.
1800 Swift Drive
Oak Brook, IL 60523
  Trustee   Trustee
since 2003
  Chairman and Chief Executive Officer of Blistex Inc., a consumer health care products manufacturer.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Member of the Heartland Alliance advisory board, a nonprofit organization serving human needs based in Chicago. Board member of the Illinois Manufacturers’ Association. Member of the Board of Visitors, Institute for the Humanities, University of Michigan.
                         
                         
Jerry D. Choate (70)
33971 Selva Road
Suite 130
Dana Point, CA 92629
  Trustee   Trustee
since 1999
  Prior to January 1999, Chairman and Chief Executive Officer of the Allstate Corporation (“Allstate”) and Allstate Insurance Company. Prior to January 1995, President and Chief Executive Officer of Allstate. Prior to August 1994, various management positions at Allstate.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of Amgen Inc., a biotechnological company, and Valero Energy Corporation, an independent refining company.
                         
 
 
23


 

                         
Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   each Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Rod Dammeyer (68)
CAC, LLC
4350 La Jolla Village Drive
Suite 685
San Diego, CA 92122-1249
  Trustee   Trustee
since 2003
  President of CAC, L.L.C., a private company offering capital investment and management advisory services.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of Quidel Corporation, Stericycle, Inc. Prior to May 2008, Trustee of The Scripps Research Institute. Prior to February 2008, Director of Ventana Medical Systems, Inc. Prior to April 2007, Director of GATX Corporation. Prior to April 2004, Director of TheraSense, Inc. Prior to January 2004, Director of TeleTech Holdings Inc. and Arris Group, Inc.
                         
                         
Linda Hutton Heagy† (61)
4939 South Greenwood
Chicago, IL 60615
  Trustee   Trustee
since 1995
  Prior to February 2008, Managing Partner of Heidrick & Struggles, an international executive search firm. Prior to 1997, Partner of Ray & Berndtson, Inc., an executive recruiting firm. Prior to 1995, Executive Vice President of ABN AMRO, N.A., a bank holding company. Prior to 1990, Executive Vice President of The Exchange National Bank.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Trustee on the University of Chicago Medical Center Board, Vice Chair of the Board of the YMCA of Metropolitan Chicago and a member of the Women’s Board of the University of Chicago.
 
 
24


 

                         
Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   each Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
                         
                         
                         
R. Craig Kennedy (57)
1744 R Street, NW
Washington, DC 20009
  Trustee   Trustee
since 1995
  Director and President of the German Marshall Fund of the United States, an independent U.S. foundation created to deepen understanding, promote collaboration and stimulate exchanges of practical experience between Americans and Europeans. Formerly, advisor to the Dennis Trading Group Inc., a managed futures and option company that invests money for individuals and institutions. Prior to 1992, President and Chief Executive Officer, Director and member of the Investment Committee of the Joyce Foundation, a private foundation.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of First Solar, Inc.
                         
                         
                         
Howard J Kerr (73)
14 Huron Trace
Galena, IL 61036
  Trustee   Trustee
since 2003
  Prior to 1998, President and Chief Executive Officer of Pocklington Corporation, Inc., an investment holding company.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of the Lake Forest Bank & Trust. Director of the Marrow Foundation.
                         
                         
                         
Jack E. Nelson (73)
423 Country Club Drive
Winter Park, FL 32789
  Trustee   Trustee
since 1986
  President of Nelson Investment Planning Services, Inc., a financial planning company and registered investment adviser in the State of Florida. President of Nelson Ivest Brokerage Services Inc., a member of the Financial Industry Regulatory Authority (“FINRA”), Securities Investors Protection Corp. and the Municipal Securities Rulemaking Board. President of Nelson Sales and Services Corporation, a marketing and services company to support affiliated companies.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex.
                         
 
 
25


 

                         
Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   each Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Hugo F. Sonnenschein (68)
1126 E. 59th Street
Chicago, IL 60637
  Trustee   Trustee
since 2003
  President Emeritus and Honorary Trustee of the University of Chicago and the Adam Smith Distinguished Service Professor in the Department of Economics at the University of Chicago. Prior to July 2000, President of the University of Chicago.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Trustee of the University of Rochester and a member of its investment committee. Member of the National Academy of Sciences, the American Philosophical Society and a fellow of the American Academy of Arts and Sciences.
 
 
26


 

                         
Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   each Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Suzanne H. Woolsey, Ph.D. (67)
815 Cumberstone Road
Harwood, MD 20776
  Trustee   Trustee
since 1999
  Chief Communications Officer of the National Academy of Sciences/National Research Council, an independent, federally chartered policy institution, from 2001 to November 2003 and Chief Operating Officer from 1993 to 2001. Prior to 1993, Executive Director of the Commission on Behavioral and Social Sciences and Education at the National Academy of Sciences/National Research Council. From 1980 through 1989, Partner of Coopers & Lybrand.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Trustee of Changing World Technologies, Inc., an energy manufacturing company, since July 2008. Director of Fluor Corp., an engineering, procurement and construction organization, since January 2004. Director of Intelligent Medical Devices, Inc., a symptom based diagnostic tool for physicians and clinical labs. Director of the Institute for Defense Analyses, a federally funded research and development center, Director of the German Marshall Fund of the United States, Director of the Rocky Mountain Institute and Trustee of California Institute of Technology and the Colorado College.
 
 
27


 

                         
Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
Interested Trustee *
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Interested Trustee   each Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Wayne W. Whalen* (69)
333 West Wacker Drive
Chicago, IL 60606
  Trustee   Trustee
since 1986
  Partner in the law firm of Skadden, Arps, Slate, Meagher & Flom LLP, legal counsel to funds in the Fund Complex.     89     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of the Abraham Lincoln Presidential Library Foundation.
 
As indicated above, prior to February 2008, Ms. Heagy was an employee of Heidrick and Struggles, an international executive search firm (“Heidrick”). Heidrick has been (and may continue to be) engaged by Morgan Stanley from time to time to perform executive searches. Such searches have been done by professionals at Heidrick without any involvement by Ms. Heagy. Ethical wall procedures exist to ensure that Ms. Heagy will not have any involvement with any searches performed by Heidrick for Morgan Stanley. Ms. Heagy does not receive any compensation, directly or indirectly, for searches performed by Heidrick for Morgan Stanley.
 
* Mr. Whalen is an “interested person” (within the meaning of Section 2(a)(19) of the 1940 Act) of certain funds in the Fund Complex by reason of he and his firm currently providing legal services as legal counsel to such funds in the Fund Complex.
 
 
28


 

Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
 
             
Officers
        Term of
   
        Office and
   
    Position(s)
  Length of
   
Name, Age and
  Held with
  Time
  Principal Occupation(s)
Address of Officer   each Fund   Served   During Past 5 Years
 
Edward C. Wood III (53)
1 Parkview Plaza – Suite 100
Oakbrook Terrace, IL 60181
  President and
Principal Executive
Officer
  Officer
since 2008
  President and Principal Executive Officer of funds in the Fund Complex since November 2008. Managing Director of Van Kampen Investments Inc., the Adviser, the Distributor, Van Kampen Advisors Inc. and Van Kampen Exchange Corp. since December 2003. Chief Administrative Officer of the Adviser, Van Kampen Advisors Inc. and Van Kampen Exchange Corp. since December 2002. Chief Operating Officer of the Distributor since December 2002. Director of Van Kampen Advisors Inc., the Distributor and Van Kampen Exchange Corp. since March 2004. Director of the Adviser since August 2008. Director of Van Kampen Investments Inc. and Van Kampen Investor Services Inc. since June 2008. Previously, Director of the Adviser and Van Kampen Investments Inc. from March 2004 to January 2005 and Chief Administrative Officer of Van Kampen Investments Inc. from 2002 to 2009.
Kevin Klingert (46)
522 Fifth Avenue
New York, NY 10036
  Vice President   Officer
since 2008
  Vice President of funds in the Fund Complex since May 2008. Global Head, Chief Operating Officer and acting Chief Investment Officer of the Fixed Income Group of Morgan Stanley Investment Management Inc. since April 2008. Head of Global Liquidity Portfolio Management and co-Head of Liquidity Credit Research of Morgan Stanley Investment Management since December 2007. Managing Director of Morgan Stanley Investment Management Inc. from December 2007 to March 2008. Previously, Managing Director on the Management Committee and head of Municipal Portfolio Management and Liquidity at BlackRock from October 1991 to January 2007.
             
             
             
Stefanie V. Chang Yu (42)
522 Fifth Avenue
New York, NY 10036
  Vice President
and Secretary
  Officer
since 2003
  Managing Director of Morgan Stanley Investment Management Inc. Vice President and Secretary of funds in the Fund Complex.
             
             
             
John L. Sullivan (53)
1 Parkview Plaza – Suite 100
Oakbrook Terrace, IL 60181
  Chief Compliance Officer   Officer
since 1996
  Chief Compliance Officer of funds in the Fund Complex since August 2004. Prior to August 2004, Director and Managing Director of Van Kampen Investments, the Adviser, Van Kampen Advisors Inc. and certain other subsidiaries of Van Kampen Investments, Vice President, Chief Financial Officer and Treasurer of funds in the Fund Complex and head of Fund Accounting for Morgan Stanley Investment Management Inc. Prior to December 2002, Executive Director of Van Kampen Investments, the Adviser and Van Kampen Advisors Inc.
 
 
29


 

             
Van Kampen Tax Free Money Fund
Trustee and Officer Information   continued
        Term of
   
        Office and
   
    Position(s)
  Length of
   
Name, Age and
  Held with
  Time
  Principal Occupation(s)
Address of Officer   each Fund   Served   During Past 5 Years
 
Stuart N. Schuldt (47)
1 Parkview Plaza – Suite 100
Oakbrook Terrace, IL 60181
  Chief Financial Officer
and Treasurer
  Officer
since 2007
  Executive Director of Morgan Stanley Investment Management Inc. since June 2007. Chief Financial Officer and Treasurer of funds in the Fund Complex since June 2007. Prior to June 2007, Senior Vice President of Northern Trust Company, Treasurer and Principal Financial Officer for Northern Trust U.S. mutual fund complex.
 
 
30


 

Your Notes


 

Your Notes


 

Your Notes


 

Van Kampen Tax Free Money Fund
An Important Notice Concerning Our
U.S. Privacy Policy
 
We are required by federal law to provide you with a copy of our Privacy Policy annually.
 
This Policy applies to current and former individual clients of Van Kampen Investments Inc., Van Kampen Asset Management, Van Kampen Advisors Inc., Van Kampen Funds Inc., Van Kampen Investor Services Inc. and Van Kampen Exchange Corp., as well as current and former individual investors in Van Kampen mutual funds, unit investment trusts, and related companies.
 
This Policy is not applicable to partnerships, corporations, trusts or other non-individual clients or account holders, nor is this Policy applicable to individuals who are either beneficiaries of a trust for which we serve as trustee or participants in an employee benefit plan administered or advised by us. This Policy is, however, applicable to individuals who select us to be a custodian of securities or assets in individual retirement accounts, 401(k) accounts, 529 Educational Savings Accounts, accounts subject to the Uniform Gifts to Minors Act, or similar accounts. Please note that we may amend this Policy at any time, and will inform you of any changes to this Policy as required by law.
 
We Respect Your Privacy
 
We appreciate that you have provided us with your personal financial information and understand your concerns about safeguarding such information. We strive to maintain the privacy of such information while we help you achieve your financial objectives. This Policy describes what nonpublic personal information we collect about you, how we collect it, when we may share it with others, and how others may use it. It discusses the steps you may take to limit our sharing of information about you with affiliated Van Kampen companies (“affiliated companies”). It also discloses how you may limit our affiliates’ use of shared information for marketing purposes. Throughout this Policy, we refer to the nonpublic information that personally identifies you or your accounts as “personal information.”
 
1. What Personal Information Do We Collect About You?
 
To better serve you and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies and from third parties and other sources. For example:
 
  •   We collect information such as your name, address, e-mail address, phone number and account title.  
 
(continued on next page)
 


 


Van Kampen Tax Free Money Fund
An Important Notice Concerning Our
U.S. Privacy Policy   continued
 
  •   We may obtain information about account balances, your use of account(s) and the types of products and services you prefer to receive from us through your dealings and transactions with us and other sources.  
 
  •   We may obtain information about your creditworthiness and credit history from consumer reporting agencies.  
 
  •   We may collect background information from and through third-party vendors to verify representations you have made and to comply with various regulatory requirements.  
 
  •   If you interact with us through our public and private Web sites, we may collect information that you provide directly through online communications (such as an e-mail address). We may also collect information about your Internet service provider, your domain name, your computer’s operating system and Web browser, your use of our Web sites and your product and service preferences, through the use of ”cookies.” ”Cookies” recognize your computer each time you return to one of our sites, and help to improve our sites’ content and personalize your experience on our sites by, for example, suggesting offerings that may interest you. Please consult the Terms of Use of these sites for more details on our use of cookies.  
 
2. When Do We Disclose Personal Information We Collect About You?
 
To provide you with the products and services you request, to better serve you, to manage our business and as otherwise required or permitted by law, we may disclose personal information we collect about you to other affiliated companies and to nonaffiliated third parties.
 
A. Information We Disclose to Our Affiliated Companies.  In order to manage your account(s) effectively, including servicing and processing your transactions, to let you know about products and services offered by us and affiliated companies, to manage our business, and as otherwise required or permitted by law, we may disclose personal information to other affiliated companies. Offers for products and services from affiliated companies are developed under conditions designed to safeguard your personal information.
 
B. Information We Disclose to Third Parties.  We do not disclose personal information that we collect about you to nonaffiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, and as otherwise required or permitted by law. For example, some instances where we may disclose information about you to third
 
(continued on next page)
 


 


Van Kampen Tax Free Money Fund
An Important Notice Concerning Our
U.S. Privacy Policy   continued
 
parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf. When we share personal information with a nonaffiliated third party, they are required to limit their use of personal information to the particular purpose for which it was shared and they are not allowed to share personal information with others except to fulfill that limited purpose.
 
3. How Do We Protect the Security and Confidentiality of Personal Information We Collect About You?
 
We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.
 
4. How Can You Limit the Sharing of Certain Types of Personal Information With Affiliated Companies?
 
We respect your privacy and offer you choices as to whether we share with affiliated companies personal information that was collected to determine your eligibility for products and services you request (“eligibility information”). Please note that, even if you direct us not to share eligibility information with affiliated companies (“opt-out”), we may still share personal information, including eligibility information, with those companies in circumstances excluded from the opt-out under applicable law, such as to process transactions or to service your account. We may also share certain other types of personal information with affiliated companies—such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us.
 
5. How Can You Limit the Use of Certain Types of Personal Information by Affiliated Companies for Marketing?
 
You may limit affiliated companies from marketing their products or services to you based on your personal information that they receive from affiliated companies. This information includes your income, assets and account history. Your choice to limit marketing offers from affiliated companies will apply until you tell us to change your choice.
 
(continued on next page)
 


 


Van Kampen Tax Free Money Fund
An Important Notice Concerning Our
U.S. Privacy Policy   continued
 
If you wish to opt-out of sharing and to limit marketing offers, you may do so by:
 
  •   Calling us at (800) 847-2424
Monday-Friday between 8 a.m. and 8 p.m. (ET)
 
 
  •   Writing to us at the following address:
Van Kampen Privacy Department
Harborside Financial Center, Plaza Two, 3rd Floor
Jersey City, NJ 07311
 
 
If you choose to write to us, your written request should include your name, address, telephone number and account number(s) to which the opt-out applies and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party.
 
If you have previously notified us about your privacy preferences, it is not necessary to do so again unless you decide to change your preferences. Your opt-out preference will remain in effect with respect to this Policy (as it may be amended) until you notify us otherwise in writing. If you have a joint account, your direction for us not to share this information with other affiliated companies and for those affiliated companies not to use your personal information for marketing will be applied to all account holders on that account.
 
Please understand that if you opt-out, you and any joint account holders may not receive information about affiliated company products and services that could help you manage your financial resources and achieve your investment objectives.
 
If you hold more than one account with Van Kampen, you may receive multiple privacy policies from us, and would need to follow the directions stated in each particular policy for each account you have with us.
 
SPECIAL NOTICE TO RESIDENTS OF VERMONT
 
This section supplements our Policy with respect to our individual clients who have a Vermont address and supersedes anything to the contrary in the above Policy with respect to those clients only.
 
The State of Vermont requires financial institutions to obtain your consent prior to sharing personal information that they collect about you with affiliated companies and nonaffiliated third parties other than in certain limited circumstances. Except as permitted by law, we will not share personal information we collect about you with nonaffiliated third parties or other affiliated companies unless you provide us with your written consent to share such information (“opt-in”).
 
(continued on back)
 


 


Van Kampen Tax Free Money Fund
An Important Notice Concerning Our
U.S. Privacy Policy   continued
 
If you wish to receive offers for investment products and services offered by or through other affiliated companies, please notify us in writing at the following address:
 
      Van Kampen Privacy Department
Harborside Financial Center, Plaza Two, 3rd Floor
Jersey City, NJ 07311
 
 
Your authorization should include your name, address, telephone number and account number(s) to which the opt-in applies and should not be sent with any other correspondence. In order to process your authorization, we require that the authorization be provided by you directly and not through a third-party.
 
 
The Statement of Additional Information includes additional information about Fund trustees and is available, without charge, upon request by calling 1-800-847-2424.
 
 
Van Kampen Funds Inc.
522 Fifth Avenue
New York, New York 10036
www.vankampen.com
 
Copyright © 2009 Van Kampen Funds Inc.
All rights reserved. Member FINRA/SIPC
 
188
TFMMANN 08/09
IU09-03437P-Y06/09
(VAN KAMPEN INVESTMENTS LOGO)
 


 

Item 2. Code of Ethics.
(a) The Fund has adopted a code of ethics (the “Code of Ethics”) that applies to its 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 Fund or a third party.
(b)   No information need be disclosed pursuant to this paragraph.
 
(c)   Due to personnel changes at the Adviser, the list of covered officers set forth in Exhibit B was amended in November 2008 and the general counsel’s designee set forth in Exhibit C was amended in April 2009. Both editions of Exhibit B and both editions of Exhibit C are attached.
 
(d)   Not applicable.
 
(e)   Not applicable.
 
(f)    
  (1)   The Fund’s Code of Ethics is attached hereto as Exhibit 12(1).
 
  (2)   Not applicable.
 
  (3)   Not applicable.
Item 3. Audit Committee Financial Expert.
The Fund’s Board of Trustees has determined that it has three “audit committee financial experts” serving on its audit committee, each of whom are “independent” Trustees : Rod Dammeyer, Jerry D. Choate and R. Craig Kennedy. Under applicable securities laws, a person who is determined to be an audit committee financial expert will not be deemed an “expert” for any purpose, including without limitation for the purposes of Section 11 of the Securities Act of 1933, as a result of being designated or identified as an audit committee financial expert. The designation or identification of a person as an audit committee financial expert does not impose on such person any duties, obligations, or liabilities that are greater than the duties, obligations, and liabilities imposed on such person as a member of the audit committee and Board of Trustees in the absence of such designation or identification.

 


 

Item 4. Principal Accountant Fees and Services.
(a)(b)(c)(d) and (g). Based on fees billed for the periods shown:
2009
                 
    Registrant     Covered Entities (1)
Audit Fees
  $ 18,400       N/A  
 
               
Non-Audit Fees
               
Audit-Related Fees
  $ 0     $ 0 (2)
Tax Fees
  $ 2,800 (3)   $ 25,300 (4)
All Other Fees
  $ 0     $ 283,445 (5)
Total Non-Audit Fees
  $ 2,800     $ 308,745  
 
               
Total
  $ 21,200     $ 308,745  
2008
                 
    Registrant     Covered Entities (1)
Audit Fees
  $ 18,400       N/A  
 
               
Non-Audit Fees
               
Audit-Related Fees
  $ 0     $ 525,100 (2)
Tax Fees
  $ 2,800 (3)   $ 59,185 (4)
All Other Fees
  $ 0     $ 401,291 (5)
Total Non-Audit Fees
  $ 2,800     $ 985,576  
 
               
Total
  $ 21,200     $ 985,576  
 
N/A- Not applicable, as not required by Item 4.
 
(1)   Covered Entities include the Adviser (excluding sub-advisors) and any entity controlling, controlled by or under common control with the Adviser that provides ongoing services to the Registrant.
 
(2)   Audit-Related Fees represent assurance and related services provided that are reasonably related to the performance of the audit of the financial statements of the Covered Entities’ and funds advised by the Adviser or its affiliates, specifically attestation services provided in connection with a SAS 70 Report.
 
(3)   Tax Fees represent tax advice and compliance services provided in connection with the review of the Registrant’s tax.
 
(4)   Tax Fees represent tax advice services provided to Covered Entities, including research and identification of PFIC entities.
 
(5)   All Other Fees represent attestation services provided in connection with performance presentation standards.


 

(e)(1) The audit committee’s pre-approval policies and procedures are as follows:
JOINT AUDIT COMMITTEE
AUDIT AND NON-AUDIT SERVICES
PRE-APPROVAL POLICY AND PROCEDURES
OF THE
VAN KAMPEN FUNDS
AS ADOPTED JULY 23, 2003 AND AMENDED MAY 26, 2004 1
1. STATEMENT OF PRINCIPLES
     The Audit Committee of the Board is required to review and, in its sole discretion, pre-approve all Covered Services to be provided by the Independent Auditors to the Fund and Covered Entities in order to assure that services performed by the Independent Auditors do not impair the auditor’s independence from the Fund. 2
     The SEC has issued rules specifying the types of services that an independent auditor may not provide to its audit client, as well as the audit committee’s administration of the engagement of the independent auditor. The SEC’s rules establish two different approaches to pre-approving services, which the SEC considers to be equally valid. Proposed services either: may be pre-approved without consideration of specific case-by-case services by the Audit Committee (“ general pre-approval ”); or require the specific pre-approval of the Audit Committee (“ specific pre-approval ”). The Audit Committee believes that the combination of these two approaches in this Policy will result in an effective and efficient procedure to pre-approve services performed by the Independent Auditors. As set forth in this Policy, unless a type of service has received general pre-approval, it will require specific pre-approval by the Audit Committee (or by any member of the Audit Committee to which pre-approval authority has been delegated) if it is to be provided by the Independent Auditors. Any proposed services exceeding pre-approved cost levels or budgeted amounts will also require specific pre-approval by the Audit Committee.
     For both types of pre-approval, the Audit Committee will consider whether such services are consistent with the SEC’s rules on auditor independence. The Audit Committee will also consider whether the Independent Auditors are best positioned to provide the most effective and efficient services, for reasons such as its familiarity with the Fund’s business, people, culture, accounting systems, risk profile and other factors, and whether the service might enhance the Fund’s ability to manage or control risk or improve audit quality. All such factors will be considered as a whole, and no one factor should necessarily be determinative.
     The Audit Committee is also mindful of the relationship between fees for audit and non-audit services in deciding whether to pre-approve any such services and may determine for each fiscal year, the appropriate ratio between the total amount of fees for Audit, Audit-related and Tax services for the Fund (including any Audit-related or Tax service fees for Covered Entities that were subject to pre-approval), and the total amount of fees for certain permissible non-audit services classified as All Other services for the Fund (including any such services for Covered Entities subject to pre-approval).
     The appendices to this Policy describe the Audit, Audit-related, Tax and All Other services that have the general pre-approval of the Audit Committee. The term of any general pre-approval is 12 months from the date of pre-approval, unless the Audit Committee considers and provides a different period and states otherwise. The Audit Committee will annually review and pre-approve the services that may be provided by the Independent Auditors without obtaining specific pre-approval from the Audit Committee. The Audit Committee will add to or subtract from the list of general pre-approved services from time to time, based on subsequent determinations.
     The purpose of this Policy is to set forth the policy and procedures by which the Audit Committee intends to fulfill its responsibilities. It does not delegate the Audit Committee’s responsibilities to pre-approve services performed by the Independent Auditors to management.
 
1   This Joint Audit Committee Audit and Non-Audit Services Pre-Approval Policy and Procedures (the “ Policy ”), amended as of the date above, supercedes and replaces all prior versions that may have been amended from time to time.
 
2   Terms used in this Policy and not otherwise defined herein shall have the meanings as defined in the Joint Audit Committee Charter.

 


 

     The Fund’s Independent Auditors have reviewed this Policy and believes that implementation of the Policy will not adversely affect the Independent Auditors’ independence.
2. Delegation
     As provided in the Act and the SEC’s rules, the Audit Committee may delegate either type of pre-approval authority to one or more of its members. The member to whom such authority is delegated must report, for informational purposes only, any pre-approval decisions to the Audit Committee at its next scheduled meeting.
3. Audit Services
     The annual Audit services engagement terms and fees are subject to the specific pre-approval of the Audit Committee. Audit services include the annual financial statement audit and other procedures required to be performed by the Independent Auditors to be able to form an opinion on the Fund’s financial statements. These other procedures include information systems and procedural reviews and testing performed in order to understand and place reliance on the systems of internal control, and consultations relating to the audit. The Audit Committee will monitor the Audit services engagement as necessary, but no less than on a quarterly basis, and will also approve, if necessary, any changes in terms, conditions and fees resulting from changes in audit scope, Fund structure or other items.
     In addition to the annual Audit services engagement approved by the Audit Committee, the Audit Committee may grant general pre-approval to other Audit services, which are those services that only the Independent Auditors reasonably can provide. Other Audit services may include statutory audits and services associated with SEC registration statements (on Forms N-1A, N-2, N-3, N-4, etc.), periodic reports and other documents filed with the SEC or other documents issued in connection with securities offerings.
     The Audit Committee has pre-approved the Audit services in Appendix B.1. All other Audit services not listed in Appendix B.1 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated).
4. Audit-related Services
     Audit-related services are assurance and related services that are reasonably related to the performance of the audit or review of the Fund’s financial statements or, to the extent they are Covered Services, the Covered Entities’ financial statements, or that are traditionally performed by the Independent Auditors. Because the Audit Committee believes that the provision of Audit-related services does not impair the independence of the auditor and is consistent with the SEC’s rules on auditor independence, the Audit Committee may grant general pre-approval to Audit-related services. Audit-related services include, among others, accounting consultations related to accounting, financial reporting or disclosure matters not classified as “Audit services”; assistance with understanding and implementing new accounting and financial reporting guidance from rulemaking authorities; agreed-upon or expanded audit procedures related to accounting and/or billing records required to respond to or comply with financial, accounting or regulatory reporting matters; and assistance with internal control reporting requirements under Forms N-SAR and/or N-CSR.
     The Audit Committee has pre-approved the Audit-related services in Appendix B.2. All other Audit-related services not listed in Appendix B.2 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated).
5. Tax Services
     The Audit Committee believes that the Independent Auditors can provide Tax services to the Fund and, to the extent they are Covered Services, the Covered Entities, such as tax compliance, tax planning and tax advice without impairing the auditor’s independence, and the SEC has stated that the Independent Auditors may provide such services. Hence, the Audit Committee believes it may grant general pre-approval to those Tax services that have historically been provided by the Independent Auditors, that the Audit Committee has reviewed and believes would not impair the independence of the Independent Auditors, and that are consistent with the SEC’s rules on auditor independence. The Audit Committee will not permit the retention of the

 


 

Independent Auditors in connection with a transaction initially recommended by the Independent Auditors, the sole business purpose of which may be tax avoidance and the tax treatment of which may not be supported in the Internal Revenue Code and related regulations. The Audit Committee will consult with Director of Tax or outside counsel to determine that the tax planning and reporting positions are consistent with this policy.
     Pursuant to the preceding paragraph, the Audit Committee has pre-approved the Tax Services in Appendix B.3. All Tax services involving large and complex transactions not listed in Appendix B.3 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated), including tax services proposed to be provided by the Independent Auditors to any executive officer or trustee/director/managing general partner of the Fund, in his or her individual capacity, where such services are paid for by the Fund (generally applicable only to internally managed investment companies).
6. All Other Services
     The Audit Committee believes, based on the SEC’s rules prohibiting the Independent Auditors from providing specific non-audit services, that other types of non-audit services are permitted. Accordingly, the Audit Committee believes it may grant general pre-approval to those permissible non-audit services classified as All Other services that it believes are routine and recurring services, would not impair the independence of the auditor and are consistent with the SEC’s rules on auditor independence.
     The Audit Committee has pre-approved the All Other services in Appendix B.4. Permissible All Other services not listed in Appendix B.4 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated).
     A list of the SEC’s prohibited non-audit services is attached to this policy as Appendix B.5. The SEC’s rules and relevant guidance should be consulted to determine the precise definitions of these services and the applicability of exceptions to certain of the prohibitions.
7. Pre-Approval Fee Levels or Budgeted Amounts
     Pre-approval fee levels or budgeted amounts for all services to be provided by the Independent Auditors will be established annually by the Audit Committee. Any proposed services exceeding these levels or amounts will require specific pre-approval by the Audit Committee. The Audit Committee is mindful of the overall relationship of fees for audit and non-audit services in determining whether to pre-approve any such services. For each fiscal year, the Audit Committee may determine the appropriate ratio between the total amount of fees for Audit, Audit-related, and Tax services for the Fund (including any Audit-related or Tax services fees for Covered Entities subject to pre-approval), and the total amount of fees for certain permissible non-audit services classified as All Other services for the Fund (including any such services for Covered Entities subject to pre-approval).
8. Procedures
     All requests or applications for services to be provided by the Independent Auditors that do not require specific approval by the Audit Committee will be submitted to the Fund’s Chief Financial Officer and must include a detailed description of the services to be rendered. The Fund’s Chief Financial Officer will determine whether such services are included within the list of services that have received the general pre-approval of the Audit Committee. The Audit Committee will be informed on a timely basis of any such services rendered by the Independent Auditors. Requests or applications to provide services that require specific approval by the Audit Committee will be submitted to the Audit Committee by both the Independent Auditors and the Fund’s Chief Financial Officer, and must include a joint statement as to whether, in their view, the request or application is consistent with the SEC’s rules on auditor independence.
     The Audit Committee has designated the Fund’s Chief Financial Officer to monitor the performance of all services provided by the Independent Auditors and to determine whether such services are in compliance with this Policy. The Fund’s Chief Financial Officer will report to the Audit Committee on a periodic basis on the results of its monitoring. A sample report is included as Appendix B.7. Both the Fund’s Chief Financial Officer and management will immediately report to the chairman of the Audit Committee any breach of this Policy that comes to the attention of the Fund’s Chief Financial Officer or any member of management.

 


 

9. Additional Requirements
     The Audit Committee has determined to take additional measures on an annual basis to meet its responsibility to oversee the work of the Independent Auditors and to assure the auditor’s independence from the Fund, such as reviewing a formal written statement from the Independent Auditors delineating all relationships between the Independent Auditors and the Fund, consistent with Independence Standards Board No. 1, and discussing with the Independent Auditors its methods and procedures for ensuring independence.
10. Covered Entities
     Covered Entities include the Fund’s investment adviser(s) and any entity controlling, controlled by or under common control with the Fund’s investment adviser(s) that provides ongoing services to the Fund(s). Beginning with non-audit service contracts entered into on or after May 6, 2003, the Fund’s audit committee must pre-approve non-audit services provided not only to the Fund but also to the Covered Entities if the engagements relate directly to the operations and financial reporting of the Fund. This list of Covered Entities would include:
  -   Van Kampen Investments Inc.
 
  -   Van Kampen Asset Management
 
  -   Van Kampen Advisors Inc.
 
  -   Van Kampen Funds Inc.
 
  -   Van Kampen Investor Services Inc.
 
  -   Morgan Stanley Investment Management Inc.
 
  -   Morgan Stanley Trust Company
 
  -   Morgan Stanley Investment Management Ltd.
 
  -   Morgan Stanley Investment Management Company
 
  -   Morgan Stanley Asset & Investment Trust Management Company Ltd.
(e)(2) Beginning with non-audit service contracts entered into on or after May 6, 2003, the audit committee also is required to pre-approve services to Covered Entities to the extent that the services are determined to have a direct impact on the operations or financial reporting of the Registrant. 100% of such services were pre-approved by the audit committee pursuant to the Audit Committee’s pre-approval policies and procedures (included herein).
(f)   Not applicable.
 
(g)   See table above.
(h) The audit committee of the Board of Trustees has considered whether the provision of services other than audit services performed by the auditors to the Registrant and Covered Entities is compatible with maintaining the auditors’ independence in performing audit services.
Item 5. Audit Committee of Listed Registrants.
(a) The Fund has a separately-designated standing audit committee established in accordance with Section 3(a)(58)(A) of the Exchange Act whose members are: R. Craig Kennedy, Jerry D. Choate, Rod Dammeyer.
(b) Not applicable.
Item 6. Schedule of Investments.
(a) Please refer to Item #1.
(b) 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.
Not applicable.
Item 11. Controls and Procedures.
(a) The Fund’s principal executive officer and principal financial officer have concluded that the Fund’s disclosure controls and procedures are sufficient to ensure that information required to be disclosed by the Fund in this Form N-CSR was recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission’s rules and forms, based upon such officers’ evaluation of these controls and procedures as of a date within 90 days of the filing date of the report.
(b) There were no changes in the registrant’s internal control over financial reporting that occurred during the 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.
(1) The Code of Ethics for Principal Executive and Senior Financial Officers is attached hereto.
(2)(a) A certification for the Principal Executive Officer of the registrant is attached hereto as part of EX-99.CERT.
(2)(b) A certification for the Principal Financial Officer of the registrant is attached hereto as part of EX-99.CERT.

 


 

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) Van Kampen Tax Free Money Fund
         
By:
  /s/ Edward C. Wood III
 
   
Name: Edward C. Wood III    
Title: Principal Executive Officer    
Date: August 20, 2009    
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
         
By:
  /s/ Edward C. Wood III
 
   
Name: Edward C. Wood III    
Title: Principal Executive Officer    
Date: August 20, 2009    
 
       
By:
  /s/ Stuart N. Schuldt
 
   
Name: Stuart N. Schuldt    
Title: Principal Financial Officer    
Date: August 20, 2009    

 

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