Federal Agencies Propose Implementation Of Volcker Rule

On October 11 and 12, several federal agencies jointly released proposed rules that would implement the so-called "Volcker Rule."¹ The Volcker Rule, which prohibits "banking entities" from certain proprietary trading and from having certain relationships with "covered funds," was originally set forth in Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which amended the Bank Holding Company Act of 1956 to add Section 13. The Volcker Rule will also impact broker-dealers affiliated with banks because these entities are considered "banking entities" under the rule.

In total, four federal agencies proposed rules: the Federal Reserve Board (Fed), the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Securities and Exchange Commission (SEC). The Commodity Futures Trading Commission (CFTC) is expected to issue a comparable proposal soon. In general, the proposed rules would