• Volcker Rule: Federal Reserve Extends Conformance Period Through July 21, 2016 for Investments in and Relationships with Legacy Covered Funds; Intends to Grant Additional Extension Through July 21, 2017
  • February 18, 2015 | Authors: Whitney A. Chatterjee; H. Rodgin Cohen; Elizabeth T. Davy; Mitchell S. Eitel; Michael T. Escue
  • Law Firm: Sullivan & Cromwell LLP - New York Office
  • Earlier today, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued an order (the “Order”) with respect to Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), commonly known as the Volcker Rule, to give all banking entities until July 21, 2016 to conform “investments in and relationships with covered funds and foreign funds” that were in place prior to December 31, 2013 (“legacy covered funds”) to the requirements of the Volcker Rule.