The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more
The five agencies that jointly issued the final Volcker Rule last December recently added to their existing list of “frequently asked questions” (FAQs) a new item addressing the attestation requirement applicable to CEOs of...more
The notorious regulation technically took effect on April 1. Covered entities must now pay closer attention to how they structure their trading activities, and their investments in fund-type vehicles. Perhaps not...more
Final regulations under the section of the Dodd-Frank Act known as the “Volcker Rule” were enacted in December 2013 (the “Final Rule”) by five federal financial regulatory agencies (collectively, the “Agencies”). The Volcker...more
The Volcker Rule, as embodied in the Dodd-Frank Act and reflected in proposed regulations, generally prohibits “banking entities” from engaging in proprietary trading and from investing in or sponsoring private equity and...more
As the U.S. bank regulatory agencies continue their efforts to implement the Volcker Rule under increasing political pressure to stiffen the Rule’s requirements, it is worth revisiting how the Rule, in its current proposed...more
The Volcker Rule prohibits a banking entity from sponsoring or investing in a hedge fund or private equity fund, subject to certain exceptions. The proposed regulations expand the definitions of “hedge fund” and “private...more