Financial Services Spotlight

Volcker Rule Developments

Posted by Roy Andersen on Jul 26, 2017 8:16:00 AM

Foreign Investment Funds

At the end of last week, the Fed and the other banking agencies issued an interpretation that applied to investments in certain foreign funds by foreign banking organizations that are subject to the Volcker rule. Such banks may control what is kno

wn as an excluded foreign fund until July 21, 2018, without having the investments made by such fund being subject to the Volcker rule. Under the Fed’s interpretation of the Volcker rule, certain investment funds sold exclusively outside the U.S. would be deemed subject to the Volcker rule if these funds were controlled by a foreign bank that was itself subject to the Volcker rule.

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Topics: Volcker Rule

Action Required Under the Volcker Rule by January 22, 2017

Posted by Roy Andersen on Dec 14, 2016 12:00:00 PM

Action Required Under the Volcker Rule by January 22, 2017.

Late Monday afternoon, the Fed announced that banks may seek an extension of time (up to five years) to hold and presumably arrange to sell their investments in or holdings of so-called “illiquid funds” that were made impermissible under the Volcker Rule.  Under the most recent relief before Monday, these investments had to be “conformed” or sold by July 21, 2017.  Many banks and banking interest groups had complained to the Fed that a variety of hedge funds and private equity funds were sold and operated to invest in “illiquid” assets and that forced sales of such investments before maturity would be a financial burden.

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Topics: Dodd-Frank, Banking, Illiquid Funds, Investment, Volcker Rule

About the Spotlight


The Financial Services Spotlight examines the regulatory and technology developments impacting banks, asset managers and other financial services providers—where challenges meet opportunities.

 

Meet the Authors


Roy C. Andersen, of counsel in Sullivan & Worcester's New York office, is a member of the Corporate Department. Mr. Andersen focuses on bank regulatory and compliance matters, including international banks and their branches and agencies in New York.

Joel Telpner, partner in the firm's New York office, is a seasoned advisor, strategist and problem solver. Mr. Telpner brings more than 30 years of legal experience in a career that includes time as an AmLaw 100 partner, the former U.S. general counsel of a global financial institution, and a venture capitalist. He is recognized for his ability to deftly manage complex financial transactions, especially those involving sophisticated structured finance and derivatives matters and has an extensive and unique combination of transactional and regulatory experience.

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