US Financial Regulators Issue Final Volcker Rule

Skadden, Arps, Slate, Meagher & Flom LLP

Brian D. Christiansen Heather Cruz Andrew M. Faulkner Laura A. Kaufmann Belkhayat William J. Sweet, Jr. Mark D. Young Maureen A. Donley

Final rule text comparison against proposal available here.

Earlier today, U.S. financial regulators issued the final Volcker Rule. The Volcker Rule implements provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that prohibit banking organizations from engaging in "proprietary trading" and making investments and conducting certain other activities with "private equity and hedge funds." The regulators released a proposed Volcker Rule in October 2011, which generated diverse and conflicting reactions from industry participants, policymakers and the public. You can find Skadden's analysis of the proposed rule here.

After more than two years, the final Volcker Rule reflects the regulators' effort to implement in a practical fashion a complex set of statutory requirements. The final rule and its accompanying materials are nearly 1,000 pages. A copy can be found here. Skadden's financial services lawyers are studying the final rule and will provide an analysis of its significance.

In the meantime, we have prepared a redline comparison of the operative text of the final rule against that of the proposed rule, which is available here.

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For up-to-date, detailed discussions on the Volcker Rule, please visit our website.

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