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Volcker Rule 2.0: Covered Funds Proposal
31 January 2020
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Yesterday, the Federal Reserve Board and the other implementing agencies proposed revisions to the Volcker Rule’s covered funds provisions.
The proposed changes generally seek to broaden and simplify the available exclusions from the covered fund definition, further limit the extraterritorial impact of the Volcker Rule on foreign funds, permit certain low-risk transactions with related covered funds that are currently prohibited under Super 23A and clarify that parallel investments made directly by a banking entity alongside a sponsored covered fund are not deemed to be investments in the fund itself.
This analysis provides our preliminary takeaways on select issues.We anticipate providing a comprehensive summary of the proposal in the future. A redline showing proposed changes to the current regulatory text is hyperlinked in our analysis.
Satish M. Kini
Gregory J. Lyons
David L. Portilla
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