Under Acting Comptroller Noreika, the OCC has asked the public for ways to revise the Volcker Rule within the boundaries of the current law. This follows suggestions to do so in the Treasury report, action by the banking agencies to forestall enforcement related to foreign funds, and a July 28 FSOC meeting at which still broader reform was discussed among the five agencies with responsibility for this complex regulation. Although carefully phrased, the request also appears to contemplate OCC actions independent of the FRB and/or FDIC should they not agree with the agency’s conclusions following this review. Many questions also directly and indirectly touch on what the statute does and does not require, fueling efforts in Congress not only to alleviate small-bank burden in this area, but also to make more dramatic changes to proprietary-trading and fund-investment policy.
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