Observations on the Volcker Funds Proposal

On January 30, the five regulatory agencies responsible for implementing the Volcker Rule approved a notice of proposed rulemaking that would make significant revisions to the “covered funds” provisions of the rule.

The Proposal would provide important new exclusions from the covered funds definition and clarify other exclusions to help address practical concerns that have limited their utility.  The Proposal aims to better tailor the application of the rule to focus on the risks the statute intended to address, and avoid interfering with other traditional banking activities, including certain activities of foreign banking organizations outside the United States.  Comments on the Proposal are due April 1, 2020. 

Please click here to read the full alert memorandum. Our highlights memo of January 31, 2020 providing a summary overview of the Proposal is also available here.