Proprietary Trading Prohibition of the Dodd-Frank Volcker Rule

October 2011


The Federal Reserve, FDIC, OCC and SEC recently issued the long-awaited proposed rule implementing the Volcker Rule of the Dodd-Frank Act. The Proposed Rule, which closely follows the language and presumptions spelled out in the Act, constructs the most far-reaching regulatory prohibition in US financial history by prohibiting proprietary trading not only in FDIC-insured institutions, but also in any affiliate thereof.

This A Closer Look focuses primarily on the proprietary trading aspects of the Proposed Volcker Rule. We cover the fund aspects of the Proposed Rule in another A Closer Look titled The Volcker Rule Proposal: Regulators Propose Restrictions on "Covered Funds". Our objective here is not to provide a detailed analysis of the Proposed Rule, but rather to try and help answer the broader question - "what should I do now?"

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