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Volcker Rule Volcker Rule

Volcker Rule Volcker Rule

Conformance Period Conformance Period

Conformance Period Conformance Period

What the Volcker Rule Covers What the Volcker Rule Covers

Financial instrument Financial instrument

Proprietary Trading Exclusions Proprietary Trading Exclusions

Permitted Proprietary Trading Permitted Proprietary Trading

Permitted Proprietary Trading (cont’d) Permitted Proprietary Trading (cont’d)

Permitted Proprietary Trading (cont’d) Permitted Proprietary Trading (cont’d)

Permitted Hedging Activities Permitted Hedging Activities

Permitted Hedging Activities (cont’d) Permitted Hedging Activities (cont’d)

Permitted Hedging Activities (cont’d) Permitted Hedging Activities (cont’d)

Permitted Market-Making Activities Permitted Market-Making Activities

Permitted Market-Making Activities (cont’d) Permitted Market-Making Activities (cont’d)

Permitted Market-Making Activities (cont’d) Permitted Market-Making Activities (cont’d)

Permitted Underwriting Activities Permitted Underwriting Activities

Permitted Underwriting Activities (cont’d) Permitted Underwriting Activities (cont’d)

Permitted Underwriting Activities (cont’d) Permitted Underwriting Activities (cont’d)

Effect on Rule 144 A transactions Effect on Rule 144 A transactions

Effect on Rule 144 A transactions (cont’d) Effect on Rule 144 A transactions (cont’d)

Permitted Trading for FBOs Permitted Trading for FBOs

Permitted trading for FBOs (cont’d) Permitted trading for FBOs (cont’d)

Permitted trading for FBOs (cont’d) Permitted trading for FBOs (cont’d)

Foreign Government Obligations Foreign Government Obligations

Deal flow under Rule 15 a-6 Deal flow under Rule 15 a-6

Prudential Backstops Prudential Backstops

Covered Funds Prohibition Covered Funds Prohibition

Sponsorship Sponsorship

Ownership Interests Ownership Interests

What is a Covered Fund? What is a Covered Fund?

Commodity Pools Commodity Pools

Foreign Covered Funds Foreign Covered Funds

What is Not a Covered Fund? What is Not a Covered Fund?

Other Exclusions Other Exclusions

What May or May Not Be a Covered Fund What May or May Not Be a Covered Fund

Permitted Activities and Investments Permitted Activities and Investments

“Super 23 A” and 23 B Restrictions “Super 23 A” and 23 B Restrictions

“Super 23 A” and 23 B Restrictions “Super 23 A” and 23 B Restrictions

Foreign Funds Foreign Funds

Foreign Covered Funds Foreign Covered Funds

Foreign Fund Exclusion Foreign Fund Exclusion

Foreign Fund Exemption Foreign Fund Exemption

Foreign Fund Exemption (cont’d) Foreign Fund Exemption (cont’d)

Investments by Foreign Funds Investments by Foreign Funds

Foreign Public Funds Foreign Public Funds

Securitization Overview Securitization Overview

Securitization Overview (cont’d) Securitization Overview (cont’d)

Securitization Overview (cont'd) Securitization Overview (cont'd)

Securitization Overview (cont'd) Securitization Overview (cont'd)

Securitization Overview (cont'd) Securitization Overview (cont'd)

Loan Securitization Exclusion Loan Securitization Exclusion

Loan Securitization Exclusion (cont’d) Loan Securitization Exclusion (cont’d)

Qualifying ABCP Conduit Exclusion Qualifying ABCP Conduit Exclusion

Qualifying Covered Bond Exclusion Qualifying Covered Bond Exclusion

Wholly Owned Subsidiary Exclusion Wholly Owned Subsidiary Exclusion

Covered Fund Problem Areas Covered Fund Problem Areas

Covered Fund Restrictions Covered Fund Restrictions

Covered Fund Restrictions (cont’d) Covered Fund Restrictions (cont’d)

Definition of “Ownership Interest” Definition of “Ownership Interest”

Definition of “Ownership Interest” (cont’d) Definition of “Ownership Interest” (cont’d)

Definition of “Ownership Interest” (cont’d) Definition of “Ownership Interest” (cont’d)

Definition of “Sponsor” Definition of “Sponsor”

Interagency Working Group Interagency Working Group

Compliance Programs Compliance Programs

Compliance Programs (cont’d) Compliance Programs (cont’d)

Enhanced Compliance Programs Enhanced Compliance Programs

Enhanced Compliance Programs (cont’d) Enhanced Compliance Programs (cont’d)

Enhanced Compliance Programs (cont’d) Enhanced Compliance Programs (cont’d)

Enhanced Compliance Programs – Risks Enhanced Compliance Programs – Risks

Enhanced Compliance Programs – Other Compliance Matters Enhanced Compliance Programs – Other Compliance Matters

Enhanced Compliance Programs (cont’d) Enhanced Compliance Programs (cont’d)

About Morrison & Foerster About Morrison & Foerster