Volcker Rule - CFTC - Comment Letter - M&T Bank Corporation - February 10, 2012

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Dodd-Frank Timeline, "Volcker Rule," CFTC
Proposal Date Comment Deadline Final Rule Released
February 14, 2012 April 16, 2012 December 10, 2013

Volcker Rule - CFTC
February 10, 2012

From the comment letter:

“Our paramount concern is that the Proposed Rule would require M&T and similar organizations to develop and implement, in extremely short order, compliance, internal controls, record-keeping and reporting regimes simply to “prove a negative”—that we are not engaged in impermissible proprietary trading. Certain aspects of the Proposed Rule, especially those that impose overly burdensome compliance cost structures on regional banks that continue to provide these ancillary services to their commercial loan clients, may inadvertently create incentives to further concentrate hedging activity in a handful of already dominant financial institutions.”

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