Volcker, For Now, Just Good Faith

April 2012


On Thursday, April 19th, the Federal Reserve Board issued a formal Policy Statement confirming that covered banking entities, “by statute,” have the full two years from July 21, 2012, i.e., until July 21, 2014, to conform all of their activities and investments to the Volcker Rule. Overall, this is an elegant administrative solution as it removes a concern that covered entities would have had to begin complying with the Volcker statute on July 21, 2012 and also provides breathing room for the Agencies to revisit the initial Volcker proposal. As with any Volcker Rule matter, there are always more questions than answers.

Contact us

Dan Ryan
US Banking and Capital Markets Leader
Tel: +1 (646) 471 8488

David Sapin
Principal, Risk and Regulatory
Tel: +1 (202) 756 1737