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    Home /  Insights /  Memos, Newsletters and Alerts /  Memo
    S&C Memos

    Office of the Comptroller of the Currency Issues Bulletin Regarding Investments in Venture Capital Funds

    Bulletin Reminds Banks of Prohibitions that Apply to Most Equity Investments in Venture Capital Funds

    November 24, 2021 | min read |
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    Yesterday, the Office of the Comptroller of the Currency (the “OCC”) issued a bulletin to remind banks that they are generally prohibited from making equity investments in venture capital funds. The bulletin applies to national banks, federal savings associations and federal branches and agencies of foreign banking organizations. It does not impact the ability of bank holding companies and non-bank subsidiaries to make investments in qualifying venture capital funds under the new exclusion from the definition of “covered fund” in the amendments to the Volcker Rule adopted in June 2020. In addition, the bulletin notes that equity investments in venture capital funds may be permissible for banks if they are public welfare investments or investments in small business investment companies.

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