Key takeaways

• On September 25, 2015, the Federal Reserve and other agencies charged with implementing the Volcker Rule issued two new Frequently Asked Questions to clarify certain aspects of the final Volcker Rule regulations.
• One of the FAQs provides guidance on the agencies’ expectations for market making in covered fund interests.  
• The second FAQ specifies the appropriate timing for the annual CEO certification required for use of the prime brokerage exception to the so-called Super 23A prohibition under the Final Rule.