Volcker Rule - Comment Letter - Consortium of Canadian Financial Institutions - January 19, 2012

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Volcker Rule
January 19, 2012

From the comment letter:

We respectfully request that the Agencies:

  • explicitly exclude from the definition of “covered fund” all Canadian and other Foreign Public Funds
  • expressly permit all Foreign Funds to exclude from the term “resident of the United States” certain omnibus accounts and non-U.S. person who are temporarily present or resident in the U.S., but otherwise eligible to invest in Foreign Funds, for purposes of the foreign fund exemption
  • narrowly interpret the term “affiliate” as used in the term “banking entity” to ensure that no fund is prohibited from engaging in trading for its own account or investing in covered funds


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