Volcker Rule: Federal Agencies Finalize Amendments to Covered Funds ProvisionsSullivan & Cromwell LLP - June 27, 2020
On June 25, 2020, the OCC, Federal Reserve, FDIC, SEC and CFTC approved a Final Rule amending the regulations implementing the Volcker Rule. The Final Rule follows a notice of proposed rulemaking issued by the Agencies in early 2020 that proposed a series of amendments to the “covered fund” provisions of the implementing regulations. The Final Rule adopts the amendments substantially as proposed, with certain targeted adjustments in response to public comments. The amendments include, among other things, new exclusions for credit funds, venture capital funds, family wealth management vehicles and customer facilitation vehicles; revisions to existing exclusions for foreign public funds, loan securitizations and public welfare and small business funds; and modifications to the “Super 23A” provisions of the Volcker Rule. The Final Rule will become effective on October 1, 2020.