Bass, Berry & Sims attorneys Tony McFarland, Brian Iverson and Annie Christoff authored an article for American Banker's Bank Think blog titled "How Smaller Banks Can Avoid Volcker Rule Headaches." The article suggests that the Volcker Rule's objective of preventing speculative trading by institutions "too big to fail" may have been lost in the regulatory process when the rule was expanded to banks of all sizes. To reduce the potential compliance burdens on small and mid-sized banks, the article provides three suggestions:
- Study the Volcker Rule regulations carefully to understand which provisions actually apply to your institution.
- Consider whether it is genuinely important to engage in the activities permitted under the Volcker Rule, such as proprietary risk-mitigating hedging activities.
- Reduce the burden of the Volcker Rule's compliance program mandate whenever possible.
To read the full article from July 16, click here.