Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation VV

Description

The Board, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Commodity Futures Trading Commission (CFTC), and the Securities and Exchange Commission (SEC) (collectively, the agencies) adopted a final rule that implemented section 13 of the Bank Holding Company Act of 1956 (BHC Act), which was added by section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Section 13 contains certain prohibitions and restrictions on the ability of a banking entity supervised by the agencies to engage in proprietary trading or to have certain interests in, or relationships with, a hedge fund or private equity fund. Section 248.20 and Appendix A of Regulation VV - Proprietary Trading and Certain Interests in and Relationships with Covered Funds require certain of the largest banking entities engaged in significant trading activities to collect, evaluate, and furnish data regarding covered trading activities as an indicator of areas meriting additional attention by the banking entity and the Board. The new FR VV-1 report must be filed by firms with 'significant' trading assets and liabilities beginning with the quarterly report for the first quarter of 2021, due April 30, 2020.