The Volcker Rule takes effect on July 21, 2012 and a recent interpretation by the Federal Reserve Board imposes a formal new requirement for a conformance plan. The “Guidance” signals the possible imposition of recordkeeping and reporting requirements before the conformance deadline in 2014.
While serving to clarify the ambiguity of the two-year period for Volcker Rule conformance, the recent issuance poses new questions. First, will the compliance deadline remain July 21, 2014? Second, will covered entities be expected to conform as soon as practicable, with the end of the two-year period serving only as the outermost deadline? Third, to what extent (if any) may a banking entity start or expand a trading or fund business after July 21, 2012, knowing that the business will be prohibited as of July 21, 2014? What, specifically, does this mean for commercial paper conduits?
Please join Carol Hitselberger and David Sahr on May 3 as they discuss these issues, the recent development and interpretation of the conformance period and what it means for banking entities in the upcoming year.
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.