Application of the Volcker Rule to Securitization & 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 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).

See: SIFMA Submits Supplemental Comments to Multiple Federal Regulators on the Volcker Rule and Securitization – May 21, 2012