Our visual memorandum here describes the proposed amendments to the Volcker Rule regulations issued by the Federal Reserve, FDIC, OCC, SEC and CFTC, as well as key requests for comment about possible additional amendments. To make the analysis more user-friendly, the memorandum incorporates elements of Davis Polk’s flowcharts on the
Continue Reading Visual Memorandum: Proposed Amendments to the Volcker Rule Regulations

The Federal Reserve held an open meeting today at which it released a proposal to modify the Volcker Rule regulations. Comments on the proposal will be due 60 days after the “date of issuance.”  The other four regulators tasked with jointly implementing the Volcker Rule regulations are expected to release
Continue Reading Proposal to Modify the Volcker Rule Regulations

Our visual memorandum here describes the key changes the Bipartisan Banking Act makes to the regulation of banking organizations. It is color coded for those who want to look only at the changes that affect their own organization.

The House is expected to pass the Economic Growth, Regulatory Relief and
Continue Reading Visual Memorandum: Bipartisan Banking Act Will Rebalance the Financial Regulatory Landscape

Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—May 2018

Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions
Continue Reading Davis Polk Financial Services Regulatory Reform Tool–March 2018

The Senate passed the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) on March 14 by a filibuster-proof vote of 67 – 31.  The Senate bill still must pass the House, where Rep. Jeb Hensarling (R-TX) and other representatives have said they plan to propose a series of amendments
Continue Reading Visual Memorandum: Senate Bipartisan Banking Bill to Rebalance the Financial Regulatory Landscape

Buried in the latest Treasury Report, the third in a series, are important gems on the Volcker Rule and on the concept of controlling influence.[1]  Of the three interesting new recommendations, two are limited to the covered funds portion of the Volcker Rule and build upon the recommendations in the
Continue Reading Treasury Asset Management and Insurance Report Makes Three Recommendations Tied to the Volcker Rule

The Office of the Comptroller of the Currency (the “OCC”) took a first formal step in evaluating how the regulations implementing the Volcker Rule should be revised by issuing a request for public input on the regulations in early August, with comments due in late September.  Of the 55 comment
Continue Reading Volcker Rule Commenters Largely Support Reforms

The Office of the Comptroller of the Currency (OCC) issued a Notice today requesting public comment on potential changes to the regulations implementing the Volcker Rule. The Notice focuses on four topics, though makes clear that the OCC invites comments on all aspects of the Volcker Rule regulations and their
Continue Reading OCC Seeks Input on Volcker Regulation Reforms

Guidelines on covered fund seeding extensions from the Federal Reserve yesterday, following on the heels of last Friday’s guidance for foreign excluded funds, is a hopeful sign that the freeze on Volcker Rule guidance is finally thawing.  Perhaps these green shoots signal that broader, common sense relief is coming.  Yesterday’s
Continue Reading Green Shoots for the Volcker Rule: a Thaw in the Guidance Freeze?