CEI Comments to Office of the Comptroller on Volcker Rule
On behalf of the Competitive Enterprise Institute (CEI), we are pleased to submit the following comments on the Office of the Comptroller of the Currency’s (OCC) proposed revision to the implementation of section 13 of the Bank Holding Company Act, commonly known as the Volcker Rule.[1] While we believe that Congress should repeal the Volcker Rule in its entirety, we applaud the OCC’s efforts to revise the rule to ease the regulatory burden – particularly on smaller banks – consistent with the framework of the statute as written.
[1] The Volcker Rule applies to banks of all sizes, which are generally required to establish an internal compliance program for two provisions: the proprietary trading provision, which prohibits banking entities from engaging in short-term trading of certain securities, derivatives, commodity futures and options on these instruments, and the “covered funds” provision, which prohibits banking entities from acquiring or retaining an ownership interest in, sponsoring, or having certain relationships with hedge funds or private equity funds.