IFLR predicted, the Volcker rule’s proposed
text and preamble has created more questions than answers.
298-page proposals released last week by four regulators
poses 383 questions – more than most senior
practitioners have seen in any rule during their career.
The industry is still formulating its response and views,
but many have distanced themselves from general propositions in
media reports claiming the rule is more moderate than expected,
and conversely, that the market making exemption is narrower
than expected. This latter claim has not been supported by
The consensus is that the long list of question signals
disagreement between the five regulators drafting the rule, and
that this is not unexpected given the statute’s
application to the real world is considered by some to be
But their effort to engage the market is commendable. "What
I think the regulators are saying is 'look, we’ve