The Administrative Procedure Act requires that the public be allowed to submit comments on new regulations. With the Volcker Rule draft, the regulators have asked over 300 questions that public, including the banks being regulated, can weigh in on.
We want to ensure that it is not just the banks weighing in on the questions posed.
What is the Volcker Rule?
What is popularly referred to as “The Volcker Rule” is Section 619 from Dodd-Frank, officially titled “Prohibitions on proprietary trading and certain relationships with hedge funds and private equity funds”.
The Volcker rule bans proprietary trading (i.e. speculation) and investments in hedge funds at government backstopped banks, but there are a large number of exceptions to the rule in the current draft, which we are concerned have the potential to be abused.
Didn’t Dodd-Frank already pass? Why are the regulators asking for comments on something that already passed?
Dodd-Frank 619 specifies that the regulators would have to follow a multi-part process to actually implement the rule. First, they were asked to create a study. You can read the results of that study here. Next, no less than eight months after the study, the regulators were required to implement Dodd-Frank 619 in a written rule. They did so in October 2011, and requested comment from interested parties on their proposed rule. Except for the CFTC’s version, the comment period is now over. The regulators now need to release a final version of the rule. This rule is currently set to go into effect on July 21st, 2012.
Where can I read your final letter?
You can read our 325-page comment letter to the SEC, FDIC, the Fed and the OCC on our website: http://www.occupythesec.org/letter/OSEC%20-%20OCC-2011-14%20-%20Comment%20Letter.pdf or on scribd: http://www.scribd.com/doc/81484886/Occupy-the-SEC-Comment-Letter-on-the-Volcker-Rule
Where can I read a summary of your final letter?
3 good summaries of @occupytheSEC’s Volcker Rule comment letter: