The financial regulatory agencies have issued a proposed rule to implement a section of S.2155 that grants an exemption from the Volcker rule for community banks that meet certain qualifications; for instance, banks that have $10 billion or less in total consolidated assets as well as trading assets and liabilities of 5 percent or less of total consolidated assets. Because the exemption became effective upon the implementation of S.2155 on May 24, 2018, the agencies have not been enforcing the Volcker Rule for these banks while waiting for the rulemaking to be finalized. Comments on the proposed rule are due April 9, 2019. The ABA has already filed comments, including proposals for clarification and modification of the community bank exclusion and the name-sharing provisions, with which CBA concurs. CBA plans on filing comments that are consistent with those made by the ABA. We invite you to review the ABA comment letter. 

If members have additional information they propose be included in CBA’s letter, either in addition to or instead of filing their own comments, please send input to Association Counsel Marty Opich on or before April 5, 2019 at mopich@westernbankers.com.

The proposed rule can be reviewed here.