Volcker Unveiled - Some Answers, More Questions

This client alert discusses issues and new developments with the issuance of the final Volcker Rule, released December 10 by the five federal agencies charged with implementing the rule. Of particular note, the alert discusses the key changes between the November 2011 proposed rule and the final rule that banks and their holding companies will have to take into account in structuring their trading and covered fund activities. Of equal importance, the alert addresses the expectations of the regulators with respect to Volcker Rule compliance programs, reporting requirements, as well as next steps regarding implementation. Finally, the alert highlights key questions and issues that remain unresolved, which we will be monitoring in the months ahead.

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