Core compliances with the Volcker Rule are nearing a July 21 deadline.
The largest institutions that are subject to the most prescriptive rules under the Volcker compliance requirements “have vast resources and dedicated teams that have been living with this for some time,” said Cliff Stanford, counsel and chair of Alston & Bird’s Bank Regulatory Group.
“They are very far along in terms of developing all the data and reporting they need to show compliance with the Volcker Rule,” he said. “There are still some uncertainties, however, that may need to be addressed regarding what compliance with a particular segment of the rule looks like.”
Banks with assets of $10 billion to $50 billion have more flexible requirements but also have fewer resources. “Many are still wrestling with it, even at this late date,” said Stanford.
“You don’t have to create an entirely new regime in most instances,” Stanford noted. “You can rely on the backbone that you already have, supplement it and make sure it can be tailored to compliance with the Volcker Rule.”
Institutions with multiple trading desks or that engage in hedging activities have been advised by examiners to designate a Volcker Rule compliance officer.
“Just like with the Bank Secrecy Act and anti-money laundering compliance, there needs to be someone who is focused on it and can help shepherd your efforts moving forward,” said Stanford.