Thank you, Chairman Schapiro.
The recommendation before us is to propose rule amendments to implement the “Volcker Rule” pursuant to Section 619 of Dodd-Frank. I am willing to support the recommendation in the interest of getting the benefit of commenters’ input, but I have significant reservations with the proposal.
Instead of engaging the particulars, let me bottom-line four of my primary concerns with the proposal. I am concerned, first, that market making-related activities and underwriting will be curtailed at the expense of liquidity and capital formation; second, that the Volcker Rule’s extraterritorial reach will put U.S. banking entities at a competitive disadvantage internationally; third, that the compliance burden and cost will prove to be excessive; and fourth, that the terms “hedge fund” and “private equity fund” were not narrowed to exclude venture capital funds from the restrictions placed on a banking entity’s covered fund activities.
Much has been and will be said about the Volcker Rule, and I very much look forward to hearing from commenters.
Again, thank you to the staff for all of your efforts on this rulemaking.