Volcker Rule Action Plan and Model Board Documents: The Conformance and Compliance Effort Begins

The recently issued final rules implementing section 619 of the Dodd-Frank Act (the "Volcker Rule") start the clock on banking entities' efforts to comply with the Volcker Rule's prohibition on short-term proprietary trading in securities or derivatives and limitation on relationships with "covered funds." Both prohibitions are subject to detailed and highly technical exceptions spelled out in the Volcker Rule and the final implementing rules. Banking entities should now turn their attention to the process of conforming investments and activities to the basic prohibitions and limitations of the Volcker Rule and establishing required governance structures and compliance programs.