Volcker Rule “1.5”: Reconsidering the Scope of the Rule

October 1, 2018

Cleary Gottlieb partner Hugh Conroy, senior counsel Edward Greene, and associate Rebecca Green authored an article titled, “Volcker Rule “1.5”: reconsidering the scope of the rule.”

The U.S. regulatory agencies responsible for implementing the Volcker Rule recently issued a proposal to address concerns raised by the existing rule, including its overbroad capture of activities and entities. This article considers whether the proposal would indeed address the rule’s overbreadth and suggests approaches that commenters could take to shape the final rule.

This article was published in Butterworths Journal of International Banking and Financial Law.