On December 18, 2014, the Federal Reserve Board announced that under section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), also known as the Volcker Rule, banking entities will be given until July 21, 2016 to conform their relationships and investments in legacy covered funds (those in place before December 31, 2014). Further, the Federal Reserve Board announced that it will grant an additional one-year extension to banking entities next year, extending the conformance period even further to July 21, 2017. Generally, Section 619 prohibits proprietary trading and acquiring or retaining ownership interests in hedge funds or private equity funds by insured depository institutions and any company affiliated with an insured depository institution. Originally, Section 619 gave entities until July 21, 2014 to conform to the requirements and later extended the period to July 21, 2015.

The Federal Reserve Board announcement is available at:

http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20141218a1.pdf