Federal Reserve Officially Extends Volcker Rule Conformance Period with Respect to “Legacy Covered Funds” to July 21, 2017

The Board of Governors of the Federal Reserve System (“Federal Reserve”), consistent with its previously announced intention, extended the conformance period with respect to investments in and relationships with covered funds and foreign funds subject to the provisions of Section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) that were in place prior to December 31, 2013 (“legacy covered funds”).

The Federal Reserve’s July 7, 2016 order (the “Order”), extends until July 21, 2017 the deadline for banking entities to conform their investments in and relationships with legacy covered funds to the Volcker Rule’s requirements. This is the last extension of the conformance period permitted by statute. The Order did not extend the conformance period for a banking entity’s investments in or relationships with covered funds made on or after December 31, 2013 or to its proprietary trading activities. Such activities were required to come into conformance by July 21, 2015.

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