Volcker Rule Interpretations Regarding Foreign Public Funds and Foreign Non-Covered Funds

SIFMA’s Asset Management Group (SIFMA AMG) wrote a letter to Scott Alvarez, General Counsel of the Board of Governors of the Federal Reserve System (Federal Reserve), requesting public guidance on Volcker Rule interpretations related to foreign public funds and foreign non-covered funds that may be banking entities.

Additionally, SIFMA AMG asked the Federal Reserve to grant a one-year extension of the conformance period with respect to all foreign funds as promptly as practicable. SIFMA believes the extension would help alleviate concerns arising out of the current lack of clarity with respect to the Volcker Rule treatment of foreign fund structures, provide the agencies charged with implementing the Volcker Rule with sufficient time to consider and act on this request and give industry participants near-term certainty as they implement their conformance strategies.