The European Banking Federation appreciates the opportunity provided by the United States Office of the Controller of the Currency’s (the “OCC”) through its request for information (RFI) to assist in determining how the regulations (the “Implementing Regulations”) implementing section 13 of the Bank Holding Company Act (the “BHC Act”), commonly referred to as the “Volcker Rule,” should be revised to better accomplish the purposes of the statute.
The EBF’s primary concern with the Implementing Regulations is their inappropriate extraterritorial reach. Since the Implementing Regulations were proposed in 2011, the EBF has urged the implementing agencies to limit the application of the Volcker Rule to activities with a U.S. nexus.
Our answer to the OCC’s RFI touches on the following two concerns: (1) how the Implementing Regulations could provide a carve-out from the banking entity definition for certain controlled foreign excluded funds; and (2) how the rule could be tailored further to focus on activities with a U.S. nexus.
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The EBF is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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