'You Know It When You See It'1
– Or Do You?
This is first in Pepper's series of Client Alerts
dealing with specific effects of the 'Volcker Rule' on
various market segments.
On December 10, 2013, after more than three years of intensive
development, the Board of Governors of the Federal Reserve System
(FRB), Office of the Comptroller of the Currency (OCC), Federal
Deposit Insurance Corporation (FDIC), the Securities and Exchange
Commission (SEC) and the Commodity Futures Trading Commission
(CFTC) adopted final regulations implementing the "Volcker
Rule," added to the Bank Holding Company Act of 1956 by
Section 619 of the Dodd-Frank Act, which prohibits banking entities
and nonbank financial companies from engaging in proprietary
trading and severely restricts their relationships with hedge funds
and private equity funds. In taking this action, the agencies have
caused a sea change in the way many financial institutions will
conduct their operations.
