August 22, 2017

August 21, 2017

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OCC Seeks Volcker Rule Comments

On August 2, the Office of the Comptroller of the Currency provided further evidence that change may be forthcoming for banks subject to the Volcker Rule (Section 13 of the Bank Holding Company Act of 1956) by issuing a notice soliciting suggestions and recommendations for revising the regulations implementing the Volcker Rule to better accomplish the purposes of the statute. All aspects of the implementing regulations are open for discussion, but the notice includes specific questions relating to 1) the scope of entities subject to the regulations; 2) the proprietary trading prohibition; 3) the covered funds prohibition; and 4) compliance programs and metrics reporting requirements.

 No changes in the implementing regulations can be made without the concurrence of the Federal Reserve, the Federal Deposit Insurance Corp, the Securities and Exchange Commission and the Commodity Futures Trading Commission. With respect to the notice, Acting Comptroller of the Currency Keith Noreika said, “I look forward to reviewing the comments and to joining the other regulators soon on a Notice of Proposed Rulemaking to amend the regulation.”

 The notice requests commenters to respond no later than 45 days after publication of the notice in the Federal Register.

 The notice is available here.

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About this Author

Guy Dempsey Jr., Bank Regulations Legal Specialist, Katten Muchin
Partner

Guy C. Dempsey Jr. concentrates his practice on derivatives and structured products and on bank regulation. He advises clients on derivatives transactions of all types across all asset classes, as well as on the corporate governance, regulatory, collateral, compliance, insolvency and litigation issues associated with such products.

Much of Guy’s work involves helping bank and non-bank clients analyze the details and impact of the Dodd-Frank Act. He maintains deep knowledge of the banking laws and regulations relating to capital markets activities....

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