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Home > News & Events > Press Releases

Joint Press Release
December 19, 2013

Agencies issue FAQ document regarding
collateralized debt obligations backed by trust
preferred securities under final rules
implementing the "Volcker rule"
Board of Governors of the Federal Reserve System
Federal Deposit Insurance Corporation
Office of the Comptroller of the Currency
For immediate release
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Three federal financial institution regulatory agencies today issued a
FAQ (Frequently Asked Questions) document to provide clarification and
guidance to banking entities regarding investments in "Covered Funds"
and whether collateralized debt obligations backed by trust preferred
securities (TruPS CDOs) could be determined to be Covered Funds
under the final rules to implement section 619 of the Dodd-Frank Wall
Street Reform and Consumer Protection Act.
The FAQs are intended to clarify that banking entities that have holdings
in TruPS CDOs are not required to sell these holdings immediately
under the final rules, but instead may use the conformance period to
determine if they can be brought into conformance by the end of the
conformance period, which is July 21, 2015.
The document released by the agencies provides an overview of some
of the key legal issues banking entities should consider in determining
whether holdings of TruPS CDOs are subject to the provision of the final
rules implementing section 619, commonly known as the Volcker Rule.

The issues identified and discussed in the document are whether a
TruPS CDO qualifies in its current form as a Covered Fund under the
final rules; whether it can be restructured or otherwise conformed to the
final rules by the end of the conformance period of July 21, 2015; and
whether a bank's investment in the CDO constitutes an ownership
interest.
The final rules were approved by the Board of Governors of the Federal
Reserve System, the Federal Deposit Insurance Corporation, the Office
of the Comptroller of the Currency, the Securities and Exchange
Commission, and the Commodity Futures Trading Commission on
December 10, 2013.
FAQ Regarding Collateralized Debt Obligations Backed by Trust
Preferred Securities under the Final Volcker rule (PDF)
Media Contacts:
Federal Reserve
Board

Barbara
Hagenbaugh

FDIC

Andrew Gray

OCC

Robert M.
Garsson

202-4522955
202-8987192
202-6496870

Last Update: December 19, 2013

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