US Agencies Responsible For Volcker Rule Implementation Release An Initial Set Of Six FAQs

On 10 June 2014, the Federal Reserve Board, the OCC, the FDIC, the Securities and Exchange Commission ("SEC"), and the Commodity Futures Trading Commission ("CFTC") issued an initial set of six joint FAQs regarding the implementation of the Volcker Rule. The FAQs address the following topics:

• the extent to which the Volcker Rule requirements (including the Tier 1 capital deduction provision for covered fund investments) apply during the conformance period;
• the extent to which the Volcker Rule requirements (including the Tier 1 capital deduction provision for covered fund investments) apply during the conformance period;
• the definition of "trading desk" and, in particular, whether a trading desk can span multiple legal entities;