Recent Bank-Affiliated Meeting(hidden)

Recaps from recent Bank-Affiliated Asset Managers Compliance Forum meetings

September 6, 2018 Conference Call

  • Discussion of Draft Comment Letter. Forum members discussed a draft comment letter on proposed amendments to the Volcker Rule, offering feedback on the arguments to be made and their consistency with those of other industry groups. The comments recommend exclusions or greater clarity with respect to certain activities that may be captured by the Volcker Rule. For example, activities relating to managers of registered funds and foreign funds, as well as seeding an exploratory product or strategy using the manager’s own capital. The comment period has been extended to October 17.

June 27, 2018 Conference Call

  • Proposed Amendments to the Volcker Rule. Forum members discussed potential comments on proposed amendments to the Volcker Rule with respect to issues that directly affect investment advisers that are affiliated with banks. The amendments would provide some relief from the Volcker Rule for such advisers that do not have significant trading assets and liabilities, and the amendments would also broaden permitted market making and hedging activities in covered funds by advisers to these covered funds. The proposal also requests comment on whether the definition of “covered fund” should be tailored further and contain additional exclusions, and whether certain exemptions from restrictions on certain inter-affiliate transactions should be incorporated.

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