On December 9, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) issued SR 16-18, “Procedures for a Banking Entity to Request an Extended Transition Period for Illiquid Funds” (“SR 1618”). A related policy statement was issued on December 12, 2016 (the “Policy Statement”).

SR 16-18 and the Policy Statement provide guidance to banking entities on the procedures for requesting from the Federal Reserve Board an extension of the Volcker Rule’s conformance period for illiquid funds. An illiquid fund is a covered fund that (1) as of May 1, 2010, was principally invested in illiquid assets or was invested in, and contractually committed to principally invest in, illiquid assets; and (2) makes all investments pursuant to an investment strategy to principally invest in illiquid assets. Requests pursuant to SR 16-18 are required to be submitted no later than January 22, 2017.