Fed Issues Proposed Rule for Conformity with Volcker Rule

Much has already been written about the possible impact of the Volcker Rule on the financial services industry. Taking an initial step in helping the market understand when the impact will come, although not yet what it will be, the Federal Reserve Board (the "Fed") on November 17, 2010 requested comment on a proposed rule to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") that give banking entities a defined period of time to conform their activities and investments to the so-called Volcker Rule. In general, the date by which banking entities must comply with new Section 13 of the Bank Holding Company Act of 1956 (the "Volcker Rule") is two years after the earlier of July 21, 2012 or the date on which the final Volcker Rule regulations are adopted. The proposal, among other things, sheds further light on how banking entities can obtain potentially very lengthy extensions beyond this initial