Agencies Release Volcker Rule FAQs on Treatment of Residual Market-Making Positions and Certain Timing Issues Related to the “Super 23A” Prohibition

The agencies responsible for implementing the Volcker Rule released two new frequently asked questions (“FAQs”). FAQ 19 relates to the treatment of certain residual market-making positions under the Volcker Rule’s proprietary trading prohibition. FAQ 20 addresses certain questions related to the timing of the application of the “Super 23A” prohibition on entering into covered transactions with related covered funds.