With FRB Chair Yellen pledging to consider Volcker Rule modifications and the Trump Administration calling for a massive overhaul, federal banking agencies have begun a cautious process to reconsider one provision they all agree needs more work:  the treatment of foreign funds as “covered” ones for purposes of Volcker prohibitions.  The notice announcing this is unusual in that it does not request comment or detail the matters under review.  Nonetheless, interested parties surely will communicate to the U.S. banking agencies as to how they wish this critical rule be implemented with regard to foreign funds offered by foreign banks for which questions about Volcker exemptions have been raised.  One business day after releasing this notice, the FRB announced how it has delegated authority to the Reserve Banks to consider requests coming from foreign and U.S. banks with regard to extensions of time needed to bring covered funds into Volcker compliance.

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