SFIG Submits Response to OCC RFI on Volcker

SFIG members submitted a response today to the Office of the Comptroller of the Currency's (OCC) request for information (RFI) regarding revisions to the Volcker Rule.

SFIG's recommendations include:

  1. Redefine covered funds more narrowly as funds that rely solely on Section 3(c)(1) or Section 3(c)(7) of the 1940 Act and that principally engage in short-term speculative trading activity;
  2. Redefine ownership interests to remove "other similar interest";
  3. Modify the Loan Securitization Exclusion (LSE) so that it (a) does not require the issuance of an ABS; (b) more clearly permits issuers relying on the LSE to hold leases and related assets; and (c) tests whether a securitization is primarily backed by loans; and
  4. Modify the "qualifying ABCP conduit" exclusion so that it (a) does not require the advising banking entity to assume all risks associated with the securities issued and (b) otherwise may be useful to more customer-facing bank sponsored ABCP issuers.

If you would like to join SFIG's Volcker Task Force, please contact Alyssa.Acevedo@sfindustry.org.

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