Proposed Implementation of Volcker Rule: Federal Reserve Requests Comment on Proposed Rule Implementing Volcker Rule Conformance Periods

Sullivan & Cromwell LLP - November 22, 2010

On November 17, 2010, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) released a proposed rule (the “Proposed Rule”) implementing the conformance periods during which banking entities and those nonbank financial companies supervised by the Federal Reserve must bring their activities and investments into compliance with the so-called “Volcker Rule” (the “Volcker Rule” or the “Rule”) provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”).  The Proposed Rule represents an initial procedural step in the inter-agency rulemaking process that will help determine the full impact of the Volcker Rule on subject financial institutions.