Legal Update: Volcker Rule Revisions Adopted by Agencies

The Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) have finalized revisions to the proprietary trading and compliance program provisions of the Volcker Rule (the “2019 Revisions”). The 2019 Revisions implement some, though not all, of the changes that had been proposed by FDIC, OCC, and other US federal banking and functional regulators in a May 2018 notice of proposed rulemaking (“2018 Proposal”). The other US federal banking and functional regulators are expected to finalize identical versions of the 2019 Revisions in the near future.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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