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The federal regulatory agencies charged with deriving and maintaining regulatory provisions pursuant to section 13 of the Bank Holding Company Act (commonly referred to as the Volcker Rule) have revised the “covered fund”...more
The five U.S. federal regulatory agencies responsible for implementing the Volcker rule — the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of the Currency (OCC), the...more
Pursuant to new Rule 139b (Rule) under the Securities Act of 1933, the publication of a “research report” on “covered investment funds” by an unaffiliated broker-dealer will not be deemed an “offer for sale or offer to sell”...more
At the end of last week, the Fed and the other banking agencies issued an interpretation that applied to investments in certain foreign funds by foreign banking organizations that are subject to the Volcker rule. Such banks...more
On July 24, 2017, the Federal Reserve Board “announced guidelines for banking entities seeking an extension to conform certain ‘seeding’ investments in hedge funds or private equity funds (‘covered funds‘) to the requirements...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
Additional guidance issued five weeks before the July 21, 2015 conformance date. On June 12, the five federal agencies jointly responsible for implementing the Volcker Rule (the Agencies) released two new “Frequently...more