The Volcker Rule has been only a skeleton in statutory form, but now is beginning to take shape as proposed regulations would flesh out its requirements. Now that the comment period on the proposed regulations has ended, a survey of the substantive suggestions for change display a variety of approaches, but at least the financial institutions directly affected have made significant, and strident, criticisms of most of the proposal. Surprisingly, many foreign governments have also weighed in because of their concern about the effect on global markets generally and on their own sovereign debt specifically. Many of these topics merit serious consideration.
View full memo, "The Comment Period Closes: What’s Next for the Volcker Rule?"