Volcker 2.0: The Promise and Pitfalls for Non U.S. Banks of Proposed Amendments to the Volcker Rule

Volcker 2.0: The Promise and Pitfalls for Non‑U.S. Banks of Proposed Amendments to the Volcker Rule Key Takeaways 1. The proposed amendments to the Volcker Rule’s implementing regulations would scale back a number of compliance requirements and, for non‑U.S. banks, would limit the Volcker Rule’s extraterritorial impact. 2. The proposed changes to the “TOTUS” exception would permit non‑U.S. banks’ trading desks outside the United States to trade with all counterparties, potentially e