Smaller banks in Volcker rule exemption letter 'stand-off'

Global banks refusing to sign representation letters with regional players


While larger foreign banks caught by the Volcker rule have detailed compliance plans at the ready, smaller institutions are relying on the "totally outside the US" (Totus) exemption but counterpart international banks are refusing to sign representation letters causing a stand-off just before the deadline for implementation.

The Volcker rule prohibits banks from conducting proprietary trading and has been part of the Dodd-Frank Act since July 2010 but comes into effect on July 21. Its scope

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