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More Volcker Rule Questions Answered

Joe Mont | September 30, 2015

The Securities and Exchange Commission has added another round of supplemental guidance to its growing list of “frequently asked questions" regarding Volcker rule compliance. The latest updates, released on Sept. 25, address CEO attestation and compliance program requirements for market making-related activities.

A summary of the questions and answers follows.

May a bank’s compliance program for market making-related activities include objective factors on which a trading desk may reasonably rely to determine whether a security is issued by a covered fund?  Also, can a market maker meet its compliance program requirements by making use of a shared utility or third party service provider to identify whether a security is issued by a covered fund?

For purposes of meeting the final rule’s exemption for market-making, a reasonably designed compliance...

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