Comment Period Extension for Volcker Rule

On December 23, the Fed, FDIC, OCC, and SEC extended the comment period on proposed regulations implementing the Volcker Rule to February 13. The Volcker Rule requires regulators to implement restrictions on the ability of banks and nonbank financial companies to engage in proprietary trading and to have certain interests in, or relationships with, hedge funds or private equity funds. Interagency Release.

SEC Division of Investment Management Letter to the North American Securities Administrators Association Indicates Possibility of Extension to Private Fund Adviser Registration Deadline Under the Dodd-Frank Act

On April 8, 2011, the Division of Investment Management of the SEC issued a letter to the North American Securities Administrators Association stating that the Division anticipates that by July 21, 2011 the SEC will complete its rulemaking implementing the provisions of the Dodd-Frank Act requiring the withdrawal of registration of certain “mid-sized advisers” and providing new exemptions for advisers that have relied upon Section 203(b)(3) of the Advisers Act, but expects in connection therewith that the SEC will “consider providing additional time for investment advisers affected . . . to come into compliance” until the first quarter of 2012. Letter.


On March 11, the FHFA announced a one-year extension of the Home Affordable Refinance Program (HARP), a program administered by Fannie Mae and Freddie Mac, to June 30, 2012. In addition, Freddie Mac will exempt HARP loans from their recently announced price adjustments and Fannie Mae will conform their eligibility date to May 2009. FHFA Release.