Volcker Rule Final Regulations: Proprietary Trading Flowcharts
Client Memorandum

Created date


Davis Polk has prepared a set of flowcharts designed to assist banking entities in identifying permissible and impermissible proprietary trading activities under the final regulations implementing the Volcker Rule, issued by the Federal Reserve, FDIC, OCC, SEC and CFTC on December 10, 2013. An introduction to the new compliance requirements is also included.

To make the summary and analysis of the final rules more user-friendly, these flowcharts graphically map the key restrictions on covered trading activities in lieu of a traditional law firm memo.

In addition to the proprietary trading flowcharts, Davis Polk flowcharts analyzing the Volcker Rule’s prohibition on banking entities sponsoring or acquiring ownership interests in hedge funds and private equity funds will be available at www.volckerrule.com.