On May 30, the Federal Reserve Board proposed revisions (the “Proposal”) to the regulations implementing section 13 of the Bank Holding Company Act (referred to as the “Volcker Rule”) and asked questions on potential additional changes. Below are our preliminary takeaways on select issues. We anticipate providing a comprehensive summary of the Proposal in the future, covering the issues below in more detail and additional issues raised by the Proposal. A redline showing proposed changes to the regulatory text is available here.
- Compliance Tailored by Size: The Proposal would establish three tiers of banking entities, based on