Federal Reserve Board Issues Volcker Rule Conformance Period Extension

The Federal Reserve Board ("Board") announced earlier today that it is extending the Volcker Rule conformance period for certain fund investments and relationships from July 21, 2015, until July 21, 2016, and that it intends next year to grant a further extension of the conformance period for such fund activities until July 21, 2017. The order granting the extension is available here.

The extension provides banking entities with additional time to conform investments in, and relationships with, (i) covered funds and (ii) foreign funds that may be subject to the provisions of section 13 (collectively, "legacy covered funds"), provided that the investment or relationship was in place prior to December 31, 2013. We interpret the reference to "foreign funds that may be subject to the provisions of section 13" as encompassing so-called "foreign non-covered funds" or "foreign excluded funds" that are controlled by a banking entity, meaning that such funds will not be