The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
The Situation: The Federal Reserve, Office of the Comptroller of the Currency ("OCC"), Federal Deposit Insurance Corporation ("FDIC"), Securities and Exchange Commission ("SEC"), and Commodity Futures Trading Commission...more
On March 31, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced that it has decided to delay the effective date of its final rules revising the Board’s framework for determining whether a...more
On Aug. 20, the Federal Deposit Insurance Corp. (the FDIC) and the Office of the Comptroller of the Currency (the OCC) approved amendments to the Volcker Rule, which restricts banking entities’ ability to engage in...more
Federal financial regulators issued a rule excluding community banks from the Volcker Rule regulations. This rule conforms the regulations to similar statutory changes enacted in May 2018. On July 9, 2019, the Board of...more
On July 17, the five main federal financial regulatory bodies — the Board of Governors of the Federal Reserve System (the Fed), the Securities and Exchange Commission, the Federal Deposit Insurance Corp., the Commodities...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
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more
Under guidance issued on July 16, 2015 by the federal agencies responsible for implementing the Volcker Rule (the “Agencies”) RICs and FPFs need not be treated as banking entities during a seeding period of up to three years....more
On July 16, 2015, the agencies responsible for implementing the Volcker rule (Agencies) issued FAQ 16, which provides guidance on the circumstances under which a seed investment would not cause (i) a registered investment...more
The Volcker rule generally prohibits banking entities from engaging in proprietary trading and from sponsoring and/or investing in certain types of “covered” investment funds. The implementing regulation that the Agencies...more
As part of the U.S. Treasury Department’s ongoing efforts to combat all forms of illicit financial activity, from terrorist financing and sanctions evasion to more traditional financial crimes (including money laundering,...more
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the “SEC”) issued a final rule, and the Commodity Futures...more
Final regulations under the section of the Dodd-Frank Act known as the “Volcker Rule” were enacted in December 2013 (the “Final Rule”) by five federal financial regulatory agencies (collectively, the “Agencies”). The Volcker...more
On December 10, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity...more
The FRB, OCC and FDIC (the “Agencies”) jointly issued a notice of proposed rulemaking (the “Proposed Rule”) that would establish a minimum liquidity coverage ratio (the “LCR”) for banking organizations with $250 billion or...more
The Federal Reserve Board on April 19 clarified that an entity covered by section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, or the so-called Volcker Rule, has the full two-year period provided by...more
An insurance company is a “covered banking entity” if it controls or is affiliated with an insured depository institution (as defined in Section 3(c) of the Federal Deposit Insurance Act), which includes any bank, thrift,...more
The Volcker Rule prohibits a banking entity from sponsoring or investing in a hedge fund or private equity fund, subject to certain exceptions. The proposed regulations expand the definitions of “hedge fund” and “private...more