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Considerations for a Volcker Rule "Private Funds" Strategy
18 June 2014
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In December 2013, the federal financial regulators adopted final regulations implementing the Volcker Rule.
In connection with the final regulations implementing the Volcker Rule, the Federal Reserve Board exercised its statutory authority to extend the two-year conformance period by one year, to July 21, 2015.
To request the first of two available one-year extensions of the conformance period, a banking entity must submit an written request to the Federal Reserve Board by January 2015.
This regulatory briefing paper, co-authored by Debevoise & Plimpton and Cogent Partners, discusses the legal standard applicable to extension requests, as well as considerations that a banking entity may want to take into account when exploring a secondary sale of fund interests, if that is an option the banking entity is considering.
This paper also discusses a number of early data gathering and organizational steps that need to be taken as soon as possible after a banking entity has made the decision to pursue a secondary sale.
Gregory J. Lyons
Satish M. Kini
David L. Portilla
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