Key takeaways

• On Monday, the Federal Reserve Board (the “FRB”) released guidance on the procedures banking entities should follow to request an extension of the one-year seeding period for a covered fund sponsored in reliance on the Volcker Rule's "asset management" exemption.
• The guidance describes how the FRB and the Federal Reserve Banks will process requests, including the criteria that will allow a Reserve Bank to act to approve an extension under delegated authority.