In August 2019, the financial services regulators responsible for the Volcker Rule regulations (the Federal Reserve Board, the Securities and Exchange Commission, the Office of the Comptroller of the Currency and the Commodity Futures Trading Commission, collectively, the Agencies) issued final rules revising the proprietary trading restrictions the Volcker Rule places on certain banking entities (the 2019 Rule). See “How Will Latest Changes to Volcker Rule Affect Non-US Banks?” NYLJ (Sept. 9, 2019).
On Feb. 28, 2020, the Agencies published a Notice of Proposed Rulemaking (NPRM) proposing changes to the “covered funds” prong of the Volcker Rule. This month’s column will touch on proposals focused on non-U.S. banks with U.S. banking operations.
Some Background
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