Section 13 of the Bank Holding Company Act (the “Volcker Rule”) and its implementing regulations (the “Implementing Regulations”) generally prohibit banking entities from engaging in proprietary trading and from investing in, sponsoring, or having certain relationships with covered funds.

On August 2, 2017, the Office of the Comptroller of the Currency (“OCC”) submitted to the Federal Register a notice requesting public comment on how the Implementing Regulations should be revised to better accomplish the purposes of the Volcker Rule while decreasing the compliance burden on banking entities and fostering economic growth (the “Notice”). The Notice also requests input concerning “how the existing rule could be implemented more effectively without revising the regulation."