A new paper titled, "When Complexity Excuses Enforcement: The Regulatory Gap in Tax-​Exempt Money Market Fund Disclosure of Municipal VRDO Deemed Reissuances," written by Michael Lissack of Tongji University, says, "This Article exposes the most egregious enforcement asymmetry in modern securities regulation: while state attorneys general and federal prosecutors pursue remarketing agents for systematic Variable Rate Demand Obligation (​VRDO) manipulation through record settlements and ongoing litigation, money market fund managers whose shareholders directly profited from these violations have entirely escaped regulatory accountability. Despite collecting billions in management fees on artificially enhanced returns generated by systematic violations, fund managers have systematically concealed obvious deemed reissuance risks from investors while regulatory authorities pursue zero enforcement actions." The summary continues, "Justice Andrew Borrok'​s April 2025 decision in State of New York ex rel. Edelweiss Fund LLC v. JPMorgan Chase & Co. eliminates all remaining excuses for this enforcement failure. The court found substantial evidence that remarketing agents' systematic '​bucketing' practices operated outside disclosed parameters -- establishing the prerequisite condition that, when combined with interest rate changes of 25 basis points or more under Treas. Reg. § 1.​1001-​3, would trigger deemed reissuances affecting the tax-​exempt status of fund distributions. This judicial validation, combined with current market volatility creating mathematical certainty of ongoing Treasury Regulation threshold breaches, makes continued regulatory inaction toward money market fund managers a dereliction of investor protection duties." It adds, "The Article establishes that regulatory authorities can no longer justify enforcement asymmetry that protects primary beneficiaries while pursuing only those who implemented violations. The evidence is overwhelming, the judicial validation of undisclosed practices is explicit, and current violations are mathematically demonstrable when these practices combine with documented rate movements. The time for regulatory complexity excuses has ended."

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