Re: Comment Letter on Proposed Revisions to Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Private Equity
Ladies and Gentlemen:
The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the proposed rule (the “Proposal”)2 to revise the regulations implementing Section 13 of the Bank Holding Company Act of 1956 (“Section 13” of the “BHC Act”), otherwise known as the Volcker Rule.
SIFMA strongly supports the Agencies’3 efforts to “improve and streamline the regulations implementing [Section 13] by modifying and clarifying requirements related to the
covered fund provisions.”4 The Proposal is a positive step forward from the 2018 proposed amendments5 to the final regulations adopted by the Agencies in December 2013 (the “2013
Final Rule”),6 in which the Agencies invited comment on a wide variety of questions as to how the covered fund provisions could be revised to make them more consistent with the text and purposes of, and more efficient in implementing, Section 13 while minimizing unnecessary burdens. We appreciate the Agencies’ consideration of our comment letter on the 2018 proposed amendments to the 2013 Final Rule (the “2018 Comment Letter”)7 and our supplemental comment letter on the proposed amendments to the 2013 Final Rule (the “2019 Supplemental Comment Letter”).