July 21, 2017 marked the date that the last of several broad extensions to the Volcker Rule’s conformance period – the two-year extension for grandfathered “legacy” covered funds – came to an end. It also marked the date that the agencies implementing the Volcker Rule (the “Agencies”) took their first step of the year – closely followed by several others – to ameliorate some of the rule’s more frustrating anomalies. All five Agencies (the Federal Reserve, OCC, FDIC, SEC and CFTC) issued a joint press release (the “Press Release”), and the three banking supervisory agencies among the Agencies (the “Banking Agencies”) issued a joint statement (the “Statement”), regarding the treatment of certain foreign excluded funds.
September 13, 2017
A Shift into Neutral – Volcker Agencies Provide Temporary Relief While Continuing to Mull Foreign Excluded Funds
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