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
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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
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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
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Ever since the final Volcker Rule regulations were made public in December 2013, foreign banks and their regulators have expressed concern about the extraterritorial reach of the Volcker Rule to certain foreign funds that have a foreign bank as sponsor or investor.  This policy issue has, as is often the
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Jay Clayton’s first public speech on Wednesday as Chairman of the SEC foretold few, if any, sweeping regulatory changes at the Commission. His remarks, delivered to the Economic Club of New York, outlined eight principles that will guide his approach to regulation, which included support for the agency’s historic
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There has been a slow start to financial regulatory reform under the Trump Administration, but the conversation is now changing in ways that are serious and thoughtful. This note highlights the key themes that we believe are important for mid-sized and regional banks in light of recent personnel announcements,
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On December 22, 2016, the Federal Reserve released a staff paper on the implementation of the Volcker Rule and its impact on bond market liquidity, particularly in times of market stress. The paper studies the liquidity of downgraded corporate bonds before and after the implementation of the Volcker Rule and
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An important, but sometimes misunderstood, SEC procedural requirement is the SEC’s quorum rule, which establishes the minimum number of Commissioners required for a Commission rulemaking.

Currently, only three of the five SEC Commissioner seats are filled. President Obama’s nominees for the two remaining slots, Hester Peirce and Lisa Fairfax,
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