Section 13 of the Bank Holding Company Act of 1956, as amended, and its implementing regulations (the “Volcker Rule”) generally prohibit a “banking entity” from engaging in proprietary trading and from investing in, sponsoring, or having certain relationships with “covered funds.”

On July 21, 2017, the Board of Governors of the Federal Reserve System (the “Board”), the Office of the Comptroller of the Currency (the “OCC”), and the Federal Deposit Insurance Corporation (the “FDIC” and, together with the Board and the OCC, the “Banking Agencies”) jointly released a Statement regarding Treatment of Certain Foreign Funds under the Rules Implementing Section 13 of the Bank Holding Company Act (the “Statement”). In issuing the Statement, the Banking Agencies consulted with staffs of the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC”).