UNITED STATES: SIFMA Supports Proposed Changes to the Volcker Rule

Thursday March 12 2020

On 11^th March 2020, SIFMA filed a comment letter on the proposed revisions to the Volcker Rule issued in January 2020. SIFMA strongly supports the proposing Agencies’ efforts to improve and streamline the regulations implementing the Volcker Rule by modifying and clarifying the requirements related to the covered fund provisions.

The Proposal addresses several aspects of the covered fund provisions that currently unduly restrict the covered fund activities of banking entities.  The proposed new exclusions from the covered fund definition, modifications to existing exclusions, and various other proposed changes would help to reduce the over-breadth and undue complexity of the covered fund provisions and are carefully tailored to ensure that otherwise proscribed activities are not done through fund structures.

In its comment letter, SIFMA makes recommendations on targeted modifications to the proposed amendments.  These include suggestions relating to new covered funds exclusions, existing exclusions, qualifying foreign excluded funds, limitations on relationships with a covered fund, parallel investments, advised covered funds, and confirmation of existing guidance.

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