FDIC and OCC Approve Volcker 2.0 — Summary of Amendments to Fund Activity Provisions

On Aug. 20, 2019, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) approved a final rule (“Final Rule”) to amend the regulations adopted in 2013 (“2013 Rule”) implementing Section 13 of the Bank Holding Company Act, commonly referred to as the “Volcker Rule.” While the Final Rule is largely similar to the Notice of Proposed Rulemaking issued by the agencies on May 30, 2019 (“Proposed Rule”), it does contain important modifications from the Proposed Rule. The other three agencies charged with implementing the Volcker Rule — the Commodity Futures Trading Commission (“CFTC”), Federal Reserve Board (“Board”) and the Securities and Exchange Commission (“SEC” together with the FDIC, OCC, CFTC and Board, “Agencies”) — are expected to approve the Final Rule in the coming days.

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