ABA Responds to Agencies’ Volcker Rule Regulatory Reform Proposal

The American Bankers Association today offered feedback to the financial regulatory agencies on proposed reforms to the Volcker Rule that would simplify the rule’s compliance burden and better target its effects toward intended activities. In the comment letter — which reflected input from three ABA-led banker working groups — the association commended the agencies for their efforts to amend the Volcker Rule regulation and highlighted several areas where more reforms are needed.

Among other things, ABA recommended that the agencies not adopt the proposed “accounting prong” and focus instead on providing meaningful improvements to the 60-day rebuttable presumption. The association also suggested additional exclusions to the “covered fund” definition, including for credit funds, long-term investment vehicles, venture capital funds and family wealth management vehicles.

In addition, ABA called for changes to Volcker’s so-called “Super 23A” provision, as well as greater interagency action and coordination in implementing regulatory reforms, including common supervisory and examination procedures.