It looks like financial institutions will have plenty of
opportunity to influence the final form of the Volcker Rule.
The leaked draft of the preamble has
highlighted a large range of ambiguities and questions
outstanding from US regulators.
The document, leaked on Wednesday, is expected to be voted
on by the Federal Deposit Insurance Corporation (FDIC) next
But the 205-page document raises almost as many questions as
it answers, containing plenty of inconsistencies. "Despite how
long the document is, I’m not sure how far
they’ve advanced beyond what the original statute
says," said Dwight Smith at Morrison & Foerster in
Once the proposal is approved and published in the federal
register, institutions will be offered a 60-day comment period.
It should be a busy two months, with scope for improvements to
Ambiguities: an infinite number more
There are certainly ambiguities. Proprietary trading,