Cadwalader attorneys authored a memorandum on the recent Federal Reserve proposal to revamp regulations implementing the Volcker Rule. The proposal was developed jointly with the other federal banking agencies, the SEC and the CFTC.
The proposed regulations are intended to (i) tailor compliance requirements and (ii) streamline and simplify how various exemptions and reporting requirements work.
The memorandum provides a detailed analysis of changes in the following areas:
- Tailoring applications by the size of a banking entity's trading assets and liabilities;
- Elimination of "enhanced" compliance program requirements;
- Changes to proprietary trading provisions;
- Limited changes to covered fund provisions; and
- Relief for foreign banks.
The attorneys further identified significant questions in the Federal Reserve's request for public comment, which is expected to remain open for at least 60 days.
The memorandum was authored by Cadwalader partners Scott Cammarn and Mark Chorazak.
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