Thursday, April 26, 2012

Fed Sets Volcker Rule Phase-In

On April 19, the Federal Reserve Board clarified that an entity covered by Volcker Rule will have the full two-year period provided by the statute to conform its activities and investments. The guidance issued by the Fed also assures covered entities and institutions that no activities or investments will be prohibited by the Volcker Rule until the end of the implementation period, currently scheduled to occur on July 21, 2014.

 
The Fed's guidance urges financial institutions covered by the rule not to wait, and start their preparations for final implementation of the Volker Rules immediately.  
 
During the conformance period, banking entities should engage in good-faith planning efforts, appropriate for their activities and investments, to enable them to conform their activities and investments to the requirements of section 619 and final implementing rules by no later than the end of the conformance period.
…all proprietary trading activity conducted by each banking entity must conform to the prohibitions and requirements of section 13 of the Bank Holding Company Act and any final implementing rules by no later than the end of the conformance period.  Similarly, all activities, investments and transactions with or involving a covered fund, including a covered fund organized and offered or sponsored by the banking entity, must conform to section 13 of the BHC Act and final implementing rules by no later than the end of the relevant conformance period.
 
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