SIFMA Supports Proposed Changes to the Volcker Rule

Washington, D.C., March 11, 2020 – SIFMA today filed a comment letter on the proposed revisions to the Volcker Rule issued in January 2020.  SIFMA strongly supports the proposing Agencies’ efforts to improve and streamline the regulations implementing the Volcker Rule by modifying and clarifying the requirements related to the covered fund provisions.

The Proposal addresses several aspects of the covered fund provisions that currently unduly restrict the covered fund activities of banking entities.  The proposed new exclusions from the covered fund definition, modifications to existing exclusions, and various other proposed changes would help to reduce the over-breadth and undue complexity of the covered fund provisions and are carefully tailored to ensure that otherwise proscribed activities are not done through fund structures.

“The proposed changes to the Volcker Rule would allow banking entities the needed flexibility to provide asset management services, customer facilitation services and financing to U.S. businesses and their customers, including start-ups, indirectly through fund structures,” said Kenneth E. Bentsen, Jr., SIFMA president and CEO.  “These changes will enable banking entities to better facilitate capital formation in an efficient and safe and sound manner, promoting U.S. economic growth and job creation.”

In its comment letter, SIFMA makes recommendations on targeted modifications to the proposed amendments.  These include suggestions relating to new covered funds exclusions, existing exclusions, qualifying foreign excluded funds, limitations on relationships with a covered fund, parallel investments, advised covered funds, and confirmation of existing guidance.

The comment letter is available here.


SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit