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University of Michigan Law School

2012

Banking and Finance Law

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The Volcker Rule's Hedging Exemption, Spencer A. Winters Sep 2012

The Volcker Rule's Hedging Exemption, Spencer A. Winters

Michigan Law Review First Impressions

The comment period for the proposed regulations to be promulgated under the Volcker Rule expired on February 13, 2012. The rulemakers received over 16,000 comments during that period, in what one commentator described as a "fecal storm." Though that description is hopefully an exaggeration, it is safe to say that the Rule's implementation has been contentious. The Volcker Rule, named for former chairman of the Federal Reserve Paul Volcker, is a component of the Dodd-Frank Act, which Congress passed in response to the recent financial crisis. The Rule's statutory provision charges the nation's financial regulators with ...