Process To Scale Back The Volcker Rule Begins

On August 2, the Office of the Comptroller of the Currency (OCC) issued a notice (the OCC Notice) seeking public comments over the next 45 days to assist in determining how the final rule implementing Section 13 of the Bank Holding Company Act (i.e., the Volcker Rule) should be revised to better accomplish the purposes of the statute. A report issued by the Department of Treasury on June 12, (the Treasury Report), identified problems with the design of the final rule and makes recommendations for revisions to the final rule, including creating a regulatory "off-ramp" for well-capitalized deposit institutions and exempting larger institutions from the proprietary trading restrictions of the Volcker Rule. Revisions to the current rule must be undertaken jointly by the OCC, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation, and in consultation and coordination with the Securities and Exchange Commission and the Commodity