Alston & Bird hosted this webinar program on February 12, 2015. The Volcker Rule generally prohibits U.S. banks and their affiliates from engaging in certain proprietary trading activities and from investing in or sponsoring certain funds. Less than six months remain to establish any required Volcker Rule compliance programs—the deadline to have such programs in place is July 21, 2015. Examiners are beginning to ask whether banks and their affiliates have assessed the need for and have built out the required compliance programs. Are you prepared? If you engage in any activities potentially covered by the Volcker Rule, now is the time to assess whether a compliance program is required so there is adequate time to put one in place before July 21, 2015, if necessary. Does your bank have a trust department? Does your bank buy, from time to time, interest rate swaps or other derivatives to hedge balance sheet risks? If the answer is “yes” to these types of questions, you may need a Volcker Rule compliance program.
Questions covered included:
- Are we required to have a Volcker Rule compliance program in place if the only trading we engage in
involves U.S. government securities?
- What steps should we be taking to determine whether all of our activities are outside the purview of the
Volcker Rule and no compliance program is required?
- What type of compliance program would be appropriate for a banking entity of our size and complexity?
- Can we adapt policies and procedures that we currently have in place to meet the requirement or are
new policies and procedures required?
Cliff Stanford is chair of the firm’s Bank Regulatory Group, providing experienced advice and strategic counsel to U.S. and foreign banks and non-bank financial services companies on the full array of regulatory concerns affecting the banking, financial services and payments industries.
Sara Lenet is a Senior Associate in the firm’s Bank Regulatory Group, advising banks, banking affiliates and other financial institutions on a variety of regulatory issues and corporate transactions.
To view a recording of the program, please click here.
February 12, 2015
12:00p.m. - 1:15p.m.