The undersigned members of the Bipartisan Policy Center’s Financial Regulatory Reform Initiative working group on Capital Markets and the Volcker Rule write to express our concern with recent reports that the five federal financial regulators (the “Agencies”) tasked with adopting Volcker Rule regulations may not adopt a single, unified set of regulations. We understand that such regulations may not be subjected to another round of notice and comment from the public, which raises concerns given the numerous questions posed by, and equally numerous responses to, the proposed regulations.
We support the policy goal underpinning the Volcker Rule: federally supported banking institutions should not engage in activities detrimental to the stability of those institutions or to U.S. financial markets. The legislative and regulatory efforts to implement the Volcker Rule have demonstrated, however, that this straightforward premise requires nuance and flexibility to be effectively applied to banking institutions with diversified businesses that operate internationally. We appreciate how difficult the task facing the Agencies is in developing regulations to implement the Volcker Rule.