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Legal Update

Proposed Regulations Implementing the Volcker Rule

20 October 2011
Mayer Brown Legal Update
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.

Authors

  • Philip O. Brandes
    T +1 212 506 2558
  • James B. Carlson
    T +1 212 506 2515
  • Carol A. Hitselberger
    T +1 704 444 3522
  • Jeffrey P. Taft
    T +1 202 263 3293
  • Jason H. P. Kravitt
    T +1 212 506 2622
  • Stuart M. Litwin
    T +1 312 701 7373
  • John W. Noell
    T +1 312 701 7179
  • Lennine Occhino
    T +1 312 701 7966
  • Stephanie M. Monaco
    T +1 202 263 3379
  • David R. Sahr
    T +1 202 263 3332
  • Jerome J. Roche
    T +1 202 263 3773
  • Donald S. Waack
    T +1 202 263 3165
  • Brad A. Resnikoff
    T +1 202 263 3110
  • Adam D. Kanter
    T +1 202 263 3164
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