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On October 11 and October 12, 2011, the Board of Governors of the Federal Reserve System (the “Board”), the Federal Deposit Insurance Corporation (the “FDIC”), the Office of the Comptroller of the Currency and the Securities and Exchange Commission (the “SEC”) issued a notice of proposed rulemaking and request for comments (the “Proposed Rule”) implementing Section 619 of the Dodd-Frank Act, also known as the “Volcker Rule.”
