Volcker, For Now, Just Good Faith

April 2012
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Volcker, For Now, Just Good Faith

At a glance

April 2012 - The Federal Reserve Board issued a formal Policy Statement on its interpretation of the conformance period provided in the Dodd-Frank Act for the Volcker Rule in which they 'confirmed' that covered entities 'by statute' have two years from July 21, 2012, to conform all of their activities and investments to the Volcker Rule.

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.

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