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Volcker Rule Update: Federal Reserve Issues Guidance on Conformance Period for Entities Engaged in Proprietary Trading or Fund Activities

04.23.12
Last week, the Federal Reserve issued a statement of policy on the period of time banking entities have to bring their activities and investments into compliance with the Volcker Rule provisions of Dodd-Frank.  While the Volcker Rule becomes effective on July 21, 2012, the key date is July 21, 2014, which is the statutory deadline by which banking entities must conform their activities and investments to the Volcker Rule.  The Federal Reserve’s recent guidance confirms that banking entities will have this entire two-year “conformance period” to come into compliance with the Volcker Rule.