Key takeaways

• On Friday, the Federal Reserve and other federal banking agencies (the “Agencies”) issued interpretive relief from the Volcker Rule’s requirements for “foreign excluded funds.”
• In short, the relief provides that for a one-year period, until July 21, 2018, a non-U.S. banking entity subject to the Volcker Rule may control a qualifying foreign excluded fund without having the activities of the fund being subject to the Volcker Rule’s prohibitions.
• The relief also resembles many aspects of an approach that we and our clients advocated the Agencies adopt. The Agencies are continuing to consider a long-term approach to this issue, which may be implemented as a part of broader regulatory reform efforts.