Milbank Financial Institutions Regulation partner Douglas Landy commented in a MarketWatch article titled, “Biggest banks prefer full Volcker Rule repeal, but a rewrite would do.” The article discussed The Office of the Comptroller of Currency’s announcement to solicit feedback on revising the Volcker Rule and how the industry is pushing Congress to fully repeal it. Mr. Landy mentions that, “a complete reversal would likely be highly disruptive and costly.” He adds, “consideration of the Volcker Rule is part of every transaction, every deal in the big banks. If the complaint is with the complexity of the rule as written, it may be better to first try to revise it.” Mr. Landy continues, “The biggest banks have hedged their bets by getting ready to live with the Volcker Rule, putting every big transaction through a ‘Volcker funnel’ to make a good faith effort at compliance” and “No bank wants to risk a headline claiming they’re flaunting the Volcker Rule.”
