In my May 9, 2012, column,1 I wrote about a proposed rule implementing one of the most controversial provisions in the Dodd-Frank Wall Street Reform and Consumer Protection Act.2 Section 619 of Dodd-Frank, the so-called “Volcker Rule,” contains prohibitions and restrictions on the ability of banking organizations and systemically significant non-bank financial companies to engage in proprietary trading or investing in or sponsoring a hedge or private equity fund.3 The rule was aimed at protecting taxpayers from losses at banking institutions protected by the “federal safety net” (e.g., FDIC deposit insurance) and at reducing risk by furthering the safety and soundness of banking institutions and lessening possible threats to the financial stability of the United States.4
On Nov. 7, 2011, the U.S. federal banking agencies and the Securities and Exchange Commission issued for comment proposed regulations to implement the Volcker Rule.5 Over two years later, after review of several thousand comments, the federal banking agencies, the Securities and Exchange Commission and the Commodity Futures Trading Commission announced approval of the final version of the Volcker Rule regulations on Dec. 10, 2013.6
