Today, the BDA sent a letter to Regulators on the Volcker Rule outlining concerns over potentially adverse market consequences which might occur as a result of an absence of harmonized common guidance should the original implementation deadline of July 21 pass without a final rule in place.
In the letter, BDA suggests that coordinated joint regulatory guidance should be issued to the marketplace as soon as possible and that there should not be any obligations imposed on market participants until the Volcker Rule is finalized. Additionally, any such guidance should set forth clear obligations of market participants during the two-year conformance period after the issuance of a final Volcker Rule. There should be few, if any, obligations imposed on market participants during this two-year conformance period.
The BDA letter is [here.]