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The IAA supported proposed amendments to the Volcker rule to conform to certain statutory amendments, but urged the Volcker Agencies to allow a limited exception on the name-sharing restrictions where the name-sharing is required or expected under local law.
The IAA made several recommendations regarding proposed revisions to the Volcker Rule Regulations, including removing the proposed accounting prong of the trading account definition and excluding all regulated funds from the banking entity definition. The IAA also made several comments related to other definitions in the proposal.
The IAA submitted a letter to the Volcker Agencies to discuss previous recommendations that had not yet been addressed, make recommendation to address concerns of bank-affiliated asset managers, and request clarification on the treatment of certain real estate funds.
The IAA raised concerns that the Volcker Regulations go beyond the purpose and intent of the Volcker Rule Statute. The IAA also recommended exclusions from certain prohibitions, updates to certain definitions, and eliminating the prohibition on name-sharing in the asset management exemption.
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