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Apr 23, 2012

Dodd-Frank’s Volcker Rule: The Federal Reserve Clarifies the Deadline for Compliance but It’s Not a Ticket to Ride

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The Federal Reserve issued a statement last week clarifying that it will interpret the Volcker Rule to afford banking entities the full two-year period provided by the statute to conform their activities and investments to the Rule’s prohibitions and restrictions. The financial services industry should welcome this alternative to curtailing trading and investment activities earlier than the statute on its face would have required, but inevitably some questions remain. The Federal Reserve still has not given any indication whether it may extend this period. As compliance activities progress and we gain greater insight into the effect of the Rule on the economy, the public may seek even clearer guidance on this aspect of the Federal Reserve’s discretion.

View full memo, "Dodd-Frank’s Volcker Rule: The Federal Reserve Clarifies the Deadline for Compliance but It’s Not a Ticket to Ride"

Authors and Contributors

Barnabas Reynolds

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5528

+44 20 7655 5528

London

Bradley K. Sabel

Of Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 8410

+1 212 848 8410

New York

Russell Sacks

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7585

+1 212 848 7585

New York

Thomas Donegan

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5566

+44 20 7655 5566

London