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January 7, 2014

The Volcker Rule: Impact on Banking Entities' Investments in Trust Preferred CDOs

Arnold & Porter Advisory

On December 10, 2013, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the Securities and Exchange Commission, and the Commodity Futures Trading Commission released final rules (the Final Rules) to implement Section 619 of the Dodd-Frank Wall Street and Consumer Protection Act, commonly known as the "Volcker Rule."

This Advisory addresses the impact that the Final Rules may have on investments by banking entities in collateralized debt obligations (CDOs) backed by trust preferred securities, which may constitute ownership interests in covered funds as those terms are defined in the Final Rules. Subsequent Advisories will address other aspects of the Final Rules in greater detail.

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