On behalf of the CFTC, the DSIO recently issued a FAQ addressing certain requirements of the Volcker Rule currently being implemented. The FAQ addresses metrics reporting dates, trading desk reporting requirements, compliance during the conformance period, loan securitization servicing assets, foreign public fund seeding vehicles and the prohibition on covered funds sharing names with banking entities. The Volcker Rule generally prohibits “banking entities”—which include FDIC-insured depository institutions, any company that controls an FDIC-insured depository institution, any company that is treated as a bank holding company and any affiliate or subsidiary of any of the above (including CFTC registrants)—from: (a) engaging in the proprietary trading of financial instruments; and (b) owning, sponsoring, or having certain relationships with hedge funds or private equity funds. In the context of derivatives, the prohibition on proprietary trading applies to futures and swaps traded by banks, and covered funds includes certain commodity pools. Both prohibitions are subject to enumerated exemptions.