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 Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures Trading...more
On June 25, 2020, the Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the "Agencies") adopted amendments (the "Amendments") to the regulations implementing section 13 of the Bank Holding Company...more
The five U.S. federal regulatory agencies responsible for implementing the Volcker rule — the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of the Currency (OCC), the...more
On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more
On Thursday, June 25, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the...more
On January 30, 2020, the Federal Reserve Board, FDIC, OCC, SEC and CFTC proposed amendments to certain Volcker Rule restrictions relating to banking entity activities with hedge funds or private equity funds (covered funds)....more
The federal agencies responsible for the Volcker Rule have proposed to clarify some requirements for exclusion from the definition of “covered fund” and to increase the types of funds excluded from that definition. The...more
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
On January 30, 2020, the U.S. Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (“Fed”), the Federal Deposit...more
Marketing Private Life Insurance Separate Accounts to Smaller Banks - Subject to certain exceptions, the so-called “Volcker rule” provisions of the Dodd-Frank Act and regulations thereunder (collectively, the Volcker Rule)...more
Proposed Changes Subject to 60-Day Comment Period - On May 30, the Federal Reserve Board of Governors voted unanimously in favor of a proposal to amend section 13 of the Bank Holding Company Act (Volcker Rule), which was...more
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...more
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...more
On July 7, 2016, the Board of Governors of the Federal Reserve System announced that it has further extended the conformance period under the Volcker rule until July 21, 2017, to allow banking entities to conform their...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
Federal Regulators Address the Scope of the Marketing Restriction in the Volcker Rule SOTUS Exemption. The federal regulatory agencies responsible for implementing the Volcker rule—The Federal Reserve Board, the...more
The political gamesmanship has begun. According to Maxine Walters “Republicans attempted to move a package of 11 bills that contained controversial changes to provisions relating to derivatives and Volcker rule. The...more
The Board of Governors of the Federal Reserve System (the Board) recently issued an order granting the second of three statutorily permitted one-year extensions for compliance by banking entities with the requirements of the...more