On March 25, the Committee submitted a comment letter to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity Futures Trading Commission regarding their notice of proposed rulemaking to revise the regulations implementing Section 13 of the Bank Holding Company Act of 1956, commonly referred to as the “Volcker Rule.”

The agencies’ proposal would revise the regulations implementing the Volcker Rule with respect to their restrictions on banking entities’ relationships with certain funds (the “covered fund provisions”). The proposal would revise both the scope of the covered fund provisions and certain restrictions contained therein. These proposed changes are “intended to improve and streamline the covered fund provisions and provide clarity to banking entities” so that they can conduct their businesses in a manner that is consistent with the Volcker Rule.

The Committee supports the agencies’ efforts to improve, streamline and clarify the covered fund provisions, and believes that the amendments set forth in the proposal further these goals. The Committee also appreciates that the proposal contains some specific revisions to the covered fund provisions that the Committee called for in its 2018 comment letter regarding the regulations implementing the Volcker Rule. In addition, the Committee recommends that the agencies further amend the covered fund provisions to exclude from the “covered fund” definition certain long-term investment funds that satisfy the conditions outlined in Question 50 of the agencies’ proposal.

The full comment letter can be found here.