The SIFMA Asset Management Group ("SIFMA AMG") and the SIFMA Private Client Group submitted a joint comment letter to the SEC on four memoranda released by the SEC Division of Economic and Risk Analysis ("DERA") regarding Money Market Fund Reforms. The four memoranda were: (i) Liquidity Cost during Crisis Periods (the "Liquidity Cost Memorandum"); (ii) Municipal Money Market Funds Exposure to Parents of Guarantors (the "Municipal MMF Memorandum"); (iii) Demand and Supply of Safe Assets in the Economy; and (iv) Government Money Market Fund Exposure to Non-Government Securities. The comment

The SEC's Division of Investment Management issued a no-action letter to several closed-end funds, stating that the SEC will not take action against any of the funds if such funds update their shelf registration statements by filing post-effective amendments under Securities Act Rule 486(b). Post-effective amendments filed pursuant to Rule 486(b) are effective on the date of filing; therefore, the funds' shelf registration statements will be continuously effective. See: No-Action Letter. Related news: Investment Management Update (July 2013).

The North American Securities Administrators Association ("NASAA") and the Conference of State Bank Supervisors ("CSBS") announced the development of model consumer guidance to assist state regulatory agencies in providing consumers with information about virtual currency and factors that consumers should consider when transacting with or investing in virtual currency. The model guidance explains what virtual currency is, provides a short list of risks that consumers should consider when investing, and reminds consumers to research what sort of regulation, if any, applies to virtual currency

The MSRB announced the topics for discussion at its April 30 - May 2 Board of Directors Meeting. The matters to be discussed include the following: Duties of Municipal Advisors: the Board will review comments received on draft Rule G-42; Municipal Advisor Political Contributions: the Board will address a possible regulation on political contributions made by municipal advisors; Best Execution: the Board will review comments received on MSRB draft Rule G-18 ("Execution of Transactions"); Dealer Professional Qualifications: The Board will review qualification exams and continuing education

Mercatus Scholar and former congressional staffer Hester Peirce published an article discussing a recent report by the U.S. Government Accountability Office ("GAO") on SEC information security controls. The GAO report identified a number of specific security weaknesses at the SEC. Lofchie Comment: One significant theme of Ms. Peirce's paper is that the SEC tends to be harder on private companies than it is on itself. Click here to view the commentary by Hester Peirce. See : GAO Report. Related news: GAO Report: SEC Needs to Improve Controls over Financial Systems and Data (April 17, 2014).