Key takeaways

• In December 2013, the federal financial regulators adopted final regulations implementing the Volcker Rule.
• In connection with the final regulations implementing the Volcker Rule, the Federal Reserve Board exercised its statutory authority to extend the two-year conformance period by one year, to July 21, 2015.
• To request the first of two available one-year extensions of the conformance period, a banking entity must submit an written request to the Federal Reserve Board by January 2015.
• This regulatory briefing paper, co-authored by Debevoise & Plimpton and Cogent Partners, discusses the legal standard applicable to extension requests, as well as considerations that a banking entity may want to take into account when exploring a secondary sale of fund interests, if that is an option the banking entity is considering.
• This paper also discusses a number of early data gathering and organizational steps that need to be taken as soon as possible after a banking entity has made the decision to pursue a secondary sale.