Volcker Rule - Comment Letter - The Clearing House - February 13, 2012

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Volcker Rule
February 13, 2012

From the comment letter:

“We urge the Agencies to reject an implementation approach for the Volcker Rule that is based on the assumption that harm to the markets, customers and financial institutions resulting from unnecessarily restrictive regulations can be corrected after the Agencies evaluate the conformance period experience… It is critical, however, that the final rules not be based on the unrealistic expectation that harmful and unintended consequences could be reversed following the conformance period. The final rules must provide a truly meaningful ability to adjust as experience and circumstances warrant. Any other approach would create the very harm to the financial system that the Dodd-Frank Act and the Volcker Rule were designed to prevent.”


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