Despite FAQs and OCC Interim Examination Procedures, Little Illumination So Far for Volcker Rule Compliance


June 2014 saw the publication of some interagency FAQs on the Volcker Rule (the Rule) and interim procedures from the Office of the Comptroller of the Currency (OCC) for its examiners to use in assessing progress by national banks and federal thrifts and federal branches and agencies of foreign banks toward compliance with the Rule. Though the latter could logically have been expected to be a harbinger of similar examination procedures from the Federal Reserve and the FDIC, more than two months later nothing of the sort has yet been released by either of those agencies.

Both of the June releases are disappointing in that they provide scant guidance for banking entities subject to the Rule, and with less than a year remaining until the July 21, 2015, compliance deadline, prospects for significant and timely illumination in the near future are rather dim. The FAQs, as discussed previously, addressed only what I called “low hanging fruit” and added relatively little guidance to what was already discernible from a study of the Prologue to the Final Rule released in December 2013. The OCC examination guidelines don’t really address the substance of the Rule but do, at least, provide some insight into what that agency’s examiners will be focusing on during the next 11 months.

In a companion article, we identify the key takeaway points from both of these issuances.

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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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