Key takeaways:

• Debevoise & Plimpton LLP led the development and publication, together with 14 other leading law firms, of the attached consensus interpretation letter setting forth our collective views on foreign bank investments in parallel fund structures under the Volcker Rule.
• The consensus letter describes the ability under the Volcker Rule of a foreign banking organization (and its affiliates) to invest in certain types of private funds organized by non-bank sponsors that invest in parallel with “covered funds” offered to US persons by the same non-bank sponsor.