Dodd Frank Update: Federal Banking Regulators Clarify Volcker Rule

On April 19, 2012, the US Federal Reserve Board ("the Federal Reserve") announced that entities subject to Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the so-called "Volcker Rule") will have until at least July 21, 2014 to bring their activities and investments into compliance with the restrictions and prohibitions of this provision of Dodd-Frank.  The Volcker Rule generally imposes restrictions on the ability of a covered banking entity to engage in proprietary trading, or to have certain types of interests in, or relationships with, hedge funds or private equity funds.

In making this much-anticipated announcement, the Federal Reserve, in coordination with the other federal agencies administering the Volcker Rule -- the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission --  sought to clarify that entities subject