The Volcker Rule's Impact On Foreign Banking Organizations

On Tuesday, December 10, 2013, the three federal banking agencies – the Board of Governors of the Federal Reserve System (the "Federal Reserve"), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation – as well as the Securities & Exchange Commission ("SEC") and the Commodity Futures Trading Commission, approved for comment a final regulation implementing Section 619 of the Dodd-Frank Act, a statutory provision more generally known as the "Volcker Rule." The 72-page final regulations¹ with the accompanying 892-page explanatory "Preamble"² were issued nearly three and a half years after the enactment of the Dodd-Frank Act, and more than two years following the proposed regulations issued in October 2011. In conjunction with the adoption of the final regulations, the Federal Reserve issued an order delaying the conformance date for Volcker for an additional year, until July 21, 2015.³