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Expert Analysis

Seeding Period Extensions After New Volcker Guidance

By V. Gerard Comizio and Nathan Brownback (July 28, 2017, 12:05 PM EDT) -- On July 24, 2017, the Division of Supervision and Regulation of the Board of Governors of the Federal Reserve System issued a letter (SR Letter 17-5)[1] providing the procedural and substantive requirements for banking entities to request extensions of the permissible seeding period for covered funds under the Volcker Rule.[2]...

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