Implementing the Private Funds Portion of the Volcker Rule

The Asset Management Group (AMG) of SIFMA provides comments to U.S. Department of the Treasury, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), the Commodity Futures Trading Commission (CFTC), and the Securities and Exchange Commission (SEC) (collectively the Agencies) in advance of the Notice of Proposed Rulemaking Implementing the Private Funds Portion of the Volcker Rule (the new section 13 of  Bank Holding Company Act of 1956).  SIFMA AMG urges the Agencies to act promptly to provide legal certainty as to which entities will actually be treated as hedge funds or private equity funds and which will be excluded, and to eliminate the internal contradictions, absurd results and unintended consequences of the private funds portion of the Volcker Rule.

SIFMA AMG submitted supplemental comments on the issue on May 9, 2011.