The regulation that will implement the Volcker Rule was finally issued on December 10, 2013. Major financial institutions around the world will have to review a host of activities and investments in order to comply with the new regime. We discuss below in detail the Rule’s prohibition on proprietary trading, its prohibition on sponsoring and investing in private funds, and the impact of these prohibitions on those banking institutions that are headquartered outside the United States. Compliance with the full regulation will be required by July 21, 2015.

Immediately below is a brief summary of the Volcker Rule and the proceedings leading to the final action. Following the summary are separate sections that explain and discuss the significant aspects of the regulation: proprietary trading, private funds, and the impact on banks headquartered outside of the United States. A brief discussion of international ramifications of the Volcker Rule follows.

Please see full memo below for more information.

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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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