By Andrew Shipe, David Freeman, Pat Doyle and George Williams (August 17, 2017, 1:14 PM EDT) -- On Aug. 1, 2017, the Office of the Comptroller of the Currency issued an advance notice of proposed rulemaking (ANPR) that represents the first concrete step toward reform of the regulations that implement the "Volcker Rule," one of the most controversial provisions of the 2010 Dodd-Frank Act. The ANPR is a short document, but its brevity belies its significance. The ANPR does not merely request comments on the rules themselves, but solicits suggestions for "improvements in the ways in which the final rule has been applied and administered to date." Thus, the comptroller appears to recognize difficulties in the practical application...
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