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Notice of Proposed Rulemaking Revising the 2013 Final Rule Implementing Section 13 of the BHC Act (the Volcker Rule)

Summary

SIFMA provides comments to the Federal Reserve, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC) on the Notice of Proposed Rulemaking Revising the 2013 Final Rule Implementing Section 13 of the BHC Act (the Volcker Rule). SIFMA supports the goal of making the Volcker Rule regulations simpler, clearer and more efficient. Section 13 should be implemented in a way that is consistent with its statutory language while minimizing unintended consequences to the economy.

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Submitted To

Federal Reserve, FDIC, OCC, SEC, CFTC

Submitted By

SIFMA

Date

17

October

2018

Excerpt

October 17, 2018
By electronic submission

Re: Comment Letter on the Notice of Proposed Rulemaking Revising the 2013 Final Rule Implementing Section 13 of the BHC Act (the Volcker Rule)

Ladies and Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to comment on the proposed rule (the “Proposal”) to revise the regulations issued by the Agencies in December 2013 (the “2013 Final Rule”)4 implementing Section 13 of the Bank Holding Company Act of 1956 (“Section 13” of the “BHC Act”), otherwise known as the Volcker Rule.

SIFMA supports the Agencies’ goal of making the Volcker Rule regulations simpler, clearer and more efficient. Section 13 should be implemented in a way that is consistent with its statutory language while minimizing unintended consequences to the economy. While many of the changes proposed would improve the implementation of Section 13, a number of them— most notably the new accounting prong—are inconsistent with the language of Section 13 and would undermine the ability of banking entities to act as intermediaries and provide liquidity in the capital markets in the ways described below. In addition, the Agencies’ proposal of so few specific amendments to the covered fund provisions undermines their stated goal.

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