Two Volcker Rule Updates: Foreign Excluded Funds and Seed Investments

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Two recent developments involving the Volcker Rule have significant implications for financial regulation in both the US and internationally.

Update 1: Temporary Relief for Certain Foreign Funds -

On July 21, 2017, the Board of Governors of the Federal Reserve System (Federal Reserve Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (together with the Federal Reserve Board and the FDIC, the Agencies) released a statement to address concerns about the potential unintended consequences and extraterritorial impact of Section 13 of the Bank Holding Company Act of 1956, as amended, and its implementing regulations (the Volcker Rule) on those foreign funds that are excluded from the “covered fund” definition (foreign excluded funds) but that may nonetheless be subject to the Volcker Rule’s proprietary trading restrictions by virtue of falling within the definition of “banking entity” as a result of being affiliated with a foreign banking entity (controlled foreign excluded funds).

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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