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White Paper

Final Regulation Implementing the Volcker Rule

18 December 2013
Mayer Brown White Paper
The US federal financial regulators recently approved the much-anticipated joint final regulation implementing the Volcker Rule, a key element of the 2010 Dodd-Frank financial reform legislation, which is intended to curtail the proprietary trading and private fund activities of US and non-US banking groups. The final regulation represents, in certain respects, a significant improvement upon the proposal released in fall 2011, particularly as it relates to limiting the extraterritorial impact of the regulation on non-US banking organizations. On the other hand, the final regulation leaves important questions from the proposal unresolved and creates new issues of its own, not least among them the manner in which Volcker Rule compliance will be supervised and enforced for complex banking organizations subject to the jurisdiction of multiple US regulators. This report summarizes the final regulation, including a banking entity’s obligations in advance of the termination of the Volcker Rule conformance period, now scheduled for July 2015, and highlights select issues of concern for many financial services firms.


  • David R. Sahr
    T +1 202 263 3332
  • Jeffrey P. Taft
    T +1 202 263 3293
  • Matthew Bisanz
    T +1 202 263 3434
  • Donald S. Waack
    T +1 202 263 3165
  • Stephanie M. Monaco
    T +1 202 263 3379
  • Adam D. Kanter
    T +1 202 263 3164
  • Philip O. Brandes
    T +1 212 506 2558
  • J. Paul Forrester
    T +1 312 701 7366
  • Carol A. Hitselberger
    T +1 704 444 3522
  • Jason H. P. Kravitt
    Senior Counsel
    T +1 212 506 2622
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