Implementation of the Volcker Rule Provisions Affecting Private Fund Sponsorship and Ownership

During the week of October 10, the Fed, the FDIC, the OCC, and the SEC proposed rules implementing Section 619 of the Dodd-Frank Act, otherwise known as the “Volcker Rule”. The Volcker Rule generally prohibits a banking entity from engaging in proprietary trading or acquiring or retaining any ownership interest in, or sponsoring a private fund. This Alert provides a summary of some of the most significant provisions of the rulemaking that directly impact the sponsorship of, and ownership of interests in, private funds by banking entities, including securitization transactions. Click here to read the full alert.