Milbank Financial Institutions Regulatory partner Douglas Landy was quoted in a recent Thompson Reuters article titled “Volcker Rule Changes Put Greater Compliance Burden on Biggest Banks; Relief Expected.” While the aim of the Federal Reserve’s proposed changes to the Volcker Rule was to simplify compliance, banks and lawyers have been weighing in with concerns on various aspects of the changes. Among the areas of concern is the introduction of a new “accounting prong” to replace the current “purpose test,” which could potentially impose increased compliance requirements on banks. Mr. Landy, a former Federal Reserve Bank of New York lawyer, notes, “what the banks have said is that the new proposal is far too broad.” Although the comment period for the proposed changes has ended, Mr. Landy states, “I have no doubt that the Federal Reserve is listening to the banks.”
