The Board of Governors of the Federal Reserve System (the “Fed”) announced its approval of a statement clarifying that an entity covered by Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Volcker Rule”) has the full two-year period provided by the statute to fully conform its activities and investments, unless the Fed further extends the conformance period. The Volcker Rule, enacted as part of the Dodd-Frank Act, imposes broad restrictions on proprietary trading and sponsoring and investing in private funds by banking entities. In an intra-agency statement, the Fed, OCC, FDIC, SEC, and CFTC stated that they will administer their oversight of banking entities under their respective jurisdictions in accordance with the Fed’s conformance rule. These agencies have invited public comment on a proposal to implement the Volcker Rule but have not yet adopted a final rule. Due to the inherent complexity of the proposal and the thousands of comment letters submitted in response to the proposal itself, several of these agencies have stated publicly that the final implementing rules may not be issued before July 21, 2012, which is the statutory effective date for the Volcker Rule. With this date fast approaching, the regulators felt it prudent to publicly confirm that the two-year conformance period will apply (at a minimum) to regulated banking entities. Notwithstanding this helpful clarification, even with this two-year conformance period, it remains a vexing question as to how banking entities can conform their activities to a yet-to-be-finalized rule.