Title

Volcker 2.1: Agencies Propose Revisions to Covered Fund Provisions
Client Memorandum

Created date

2/3/2020

On January 30, 2020, the Federal Reserve Board, OCC, FDIC, SEC and CFTC (the Agencies) proposed amendments to the covered fund provisions of the Volcker Rule. The proposed amendments address long-standing concerns with the over-broad definition of covered fund, the treatment of foreign funds (both public and private), and the Super 23A prohibition.