Volcker Rule Resource Center



Executive Summary of SIFMA's Comments on the Proposed Volcker Rule

The comment period for the proposed Volcker Rule, as mandated by the Dodd-Frank Act, closed on February 13, 2012. On behalf of our members, SIFMA offered several ideas to multiple federal regulators to better implement the Rule, all in compliance with Congressional intent but without damaging the liquidity and resiliency of U.S. capital markets.

In total, SIFMA submitted five detailed comment letters related to various provisions of the proposal. Jump to executive summaries on provisions related to:

 

SIFMA and Other Associations Submit Comments to Multiple Federal Regulators on the Proprietary Trading Provisions of the Volcker Rule

SIFMA, The Clearing House (TCH), The Financial Services Roundtable (FSR), and the American Bankers Association (ABA) provide comments to multiple federal regulatory agencies on the proprietary trading provisions of the proposed rules implementing new Section 13 of the Bank Holding Company Act of 1956 (the Volcker Rule).

 

SIFMA AMG Submits Comments to Multiple Federal Regulators on Provisions of the Volcker Rule Relating to Proprietary Trading 

The Asset Management Group (AMG) of SIFMA provides comments to multiple federal regulators on the proposed restrictions on proprietary trading (the Volcker Rule) and the impacts that the proposed rule would have on market liquidity.

 

SIFMA and Other Associations Submit Comments to Multiple Federal Regulators on the Provisions of the Volcker Rule Relating to Private Funds Restrictions

SIFMA, The Clearing House (TCH), The Financial Services Roundtable (FSR), and the American Bankers Association (ABA) provide comments to multiple federal regulators on proposed rulemaking implementing the Volcker Rule, specifically commenting on provisions related to hedge funds and private equity funds.

 

SIFMA Submits Comments to Multiple Federal Regulators on the Provisions of the Volcker Rule Relating to Municipal Securities

SIFMA provides comments to multiple federal regulators on proposed rulemaking to implement Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. This comment letter focuses specifically on: municipal securities and tender option bonds, which are a specific type of transaction described herein that involves the repackaging of municipal securities that is common in the marketplace.

 

SIFMA Submits Comments to Multiple Federal Regulators on the Application of the Volcker Rule to Securitization and Insurance-Linked Securities Transactions

SIFMA provides comments to the Comptroller of the Currency, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC) on proposed rules implementing new Section 13 of the Bank Holding Company Act of 1956 (the Volcker Rule). The Volcker Rule was added by Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). This comment letter relates solely to certain provisions of the proposed rules that affect the treatment of asset-backed securities (ABS) and insurance-linked securities (ILS).


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