The Volcker Rule Proposal: Challenges, Open Issues and Unintended Consequences

We have prepared the attached memorandum analyzing key implications of the proposal for market participants in the areas of proprietary trading, funds activities, employee compensation arrangements, and securitization. The memorandum includes a brief overview of high-level implications, key takeaways and specific highlights of the proposal, followed by a detailed outline discussing specific challenges, unintended consequences and interpretive questions throughout the proposal that should be addressed in comments and considered as businesses prepare for the July 2012 effective date.