On June 25, 2020, five federal financial regulatory agencies published the long-awaited Final Revisions to the Volcker Rule (the “Final Revisions”), which revise certain aspects of the Volcker Rule with respect to the identification and treatment of covered funds, including the “Super 23A” prohibition. The Final Revisions follow three years of the agencies’ consideration of changes to the Volcker Rule, originally prompted by the June 2017 Treasury Report that solicited changes to ease the compliance burden on banks. The Final Revisions are largely consistent with the notice of proposed rulemaking published six months ago but with some important, and welcome, clarifications and other adjustments. Many of the changes that are contained in the Final Revisions are in response to requests from the structured finance industry that were designed to clarify and ease the compliance burden of banking entities subject to the Volcker Rule.

Please join Mayer Brown partners Thomas Delaney, Carol Hitselberger and Jeffrey Taft, and associate Matthew Bisanz, for a discussion of the revisions to the Volcker Rule.

Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.

Listen to Volcker Rule Revisions: Easing the Compliance Burden for Structured Finance.