On Wednesday, October 17th, the American Investment Council submitted the letter of comment to officials at the Federal Reserve, CFTC, FDIC, OCC, and SEC regarding the Volcker Rule. Our letter expresses appreciation for the Agencies’ goal to simplify and tailor the final regulations, describes why we support certain proposed modifications that would remove unnecessary barriers to investment, and provides recommendations for ways the Volcker Rule should be revised.
Our letter specifically references three regulatory issues:
- Covered Fund Definition
- Codification of Existing Guidance on the Marketing Restriction
- Foreign Excluded Funds
Our comments are focused on ensuring that the Volcker Rule achieves its purposes to:
- ensure consistent treatment of funds with long-term investment strategies where investors do not have redemption rights;
- create mechanisms to make it easier for banking entities to make permissible investments in third-party sponsored vehicles;
- and minimize interference with, and compliance burdens imposed on, non-bank fund sponsors.