The US bank and securities regulatory agencies have issued for public comment their much anticipated proposal to implement the Volcker Rule provisions of the Dodd-Frank Act. The proposal provides key details—and raises many new questions—regarding the proprietary-trading and covered-fund prohibitions at the core of the Volcker Rule, as well as the restrictions and conditions that will apply to banking entities that engage in permitted trading and fund activities pursuant to its key exemptions. This Legal Report summarizes the proposal and highlights select issues of concern to many financial services firms, including observations regarding the extraterritorial reach of the proposal and its potential impact on the securitization markets.

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