Volcker Rule - Comment Letter - Securities Industry and Financial Markets Association - February 13, 2012

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Volcker Rule
February 13, 2012

In the comment letter, SIFMA recommends that the Agencies modify the Proposed Rules as follows:

  • Because ABS Issuers are not hedge funds or private equity funds, the Agencies should, as intended by the Securitization Exclusion, exclude such issuers from the Proposed Rules’ definition of “covered funds”
  • Further, because we do not believe issuers of insurance-linked securities were intended to be “covered funds” under the Volcker Rule, the Agencies should exclude ILS Issuers from such definition.


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