Bracing For Volcker

Law360, New York (December 8, 2011, 1:23 PM EST) -- On Jan. 13, 2012, comments are due on the controversial interagency Volcker Rule proposal issued by the U.S. Securities and Exchange Commission, Federal Reserve Board (FRB), Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the “agencies”).[1] Taking into account the many issues raised in the proposal, including almost 400 questions for public comment, there is significant uncertainty regarding the direction the agencies will take in implementing the rule’s restrictions on bank proprietary trading and covered fund activities.

The uncertainty is exacerbated...
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