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

Sullivan & Cromwell LLP - November 24, 2021

Yesterday, the Office of the Comptroller of the Currency issued a bulletin to remind banks that they are generally prohibited from making equity investments in venture capital funds. The bulletin 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.
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