As a result of both legislative mandates as well as Congressional and public concern, the Board of Governors of the Federal Reserve System (Board) has been examining whether to impose new restrictions on the activities of banks related to physical commodities. Following these examinations, the Board recently took two actions designed to impose new limits on the activities of banks related to physical commodities: (i) a notice of proposed rulemaking to impose new capital requirements and other limits on such activities of financial holding companies (FHCs) (the “proposed rule”); and (ii) a report, issued pursuant to Section 620 of the Dodd-Frank Act (620 Report), which contains recommendations for legislation to repeal several current authorities for banks to engage in physical commodities activities.