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Volcker Rule: Temporary Relief for Foreign Excluded Funds
24 July 2017
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On Friday, the Federal Reserve and other federal banking agencies (the “Agencies”) issued interpretive relief from the Volcker Rule’s requirements for “foreign excluded funds.”
In short, the relief provides that for a one-year period, until July 21, 2018, a non-U.S. banking entity subject to the Volcker Rule may control a qualifying foreign excluded fund without having the activities of the fund being subject to the Volcker Rule’s prohibitions.
The relief also resembles many aspects of an approach that we and our clients advocated the Agencies adopt. The Agencies are continuing to consider a long-term approach to this issue, which may be implemented as a part of broader regulatory reform efforts.
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