OCC Seeks Input on Volcker Regulation Reforms
Client Memorandum

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The Office of the Comptroller of the Currency (OCC) issued a Notice today requesting public comment on potential changes to the regulations implementing the Volcker Rule.  The Notice focuses on four topics—the scope of entities subject to the Volcker Rule, the definition of proprietary trading and scope of exemptions from that definition, the covered fund definition and Super 23A provisions, and compliance program and metrics—though makes clear that the OCC invites comments on all aspects of the Volcker Rule regulations and their administration.  Comments are due 45 days after the Notice is published in the Federal Register.