Volcker compliance-responsibility aspect splits legal opinion

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Dwight Smith of Morrison & Foerster

The concept of personal executive responsibility for compliance with the Volcker rule could be dropped from the final rules on implementation of the US Dodd-Frank Act when they are published later this year.

The initial Treasury proposal states that a firm's chief executive must give "public attestation of compliance" with the Volcker rule, but observers disagree on whether this clause will make it into the final version.

"I expect the concept to survive, as it is consistent with requirements in

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