SIFMA, ISDA, the Futures Industry Association, and other
industry trade associations and a diverse group of banking
organizations made recommendations on proposed
changes to regulations implementing Section 13 of the
Bank Holding Company Act, also known as the "Volcker
Rule." The comment period ended on October 17, 2018.
SIFMA asserted that the proposal is inconsistent
with the statutory language and could have unintended negative
consequences for the capital markets economy by restricting
liquidity of banking entities. SIFMA said the proposal would leave
untouched the "overbroad" definition of "covered
fund," which continues to interfere with banking entities'
ability to provide certain financing and asset management services.
SIFMA's Municipal Securities Division filed a separate comment letter that addressed the interaction
between the Volcker Rule and municipal Tender Option Bonds, a tool
used by banks to support market liquidity that SIFMA believes
should be