In my July 2018 column, I discussed proposed changes to the Volcker Rule regulations issued for comment by the federal banking, commodities and securities regulators (collectively, the Agencies). As most readers will know, the Volcker Rule (§13 of the Bank Holding Company (BHC) Act) and its implementing regulations (jointly with §13 of the BHC Act, the Volcker Rule) prohibit “banking entities” (generally, insured banks and their affiliates, and non-U.S. banks with U.S. banking operations) from engaging in proprietary trading or sponsoring or investing in private equity funds (covered funds).

In my January 2019 column, I discussed some comments on the proposal that had been submitted by non-U.S. banks on issues of particular importance to them.