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The disruptions in economic conditions caused by the coronavirus disease 2019 (COVID-19) are reaching the commercial paper and longer term debt capital  markets.  The Board of Governors of the Federal Reserve System (Federal Reserve) has already set into motion three separate facilities as part of its effort to facilitate credit and help alleviate collateral volatility

On January 30, 2020, five federal financial regulatory agencies published the long awaited notice of proposed rulemaking (the “NPR”) to revise certain aspects of the Volcker Rule (Section 13 of the Bank Holding Company Act) with respect to the treatment of covered funds.  The NPR follows over 2 ½ years of the agencies’ consideration of changes to the Volcker Rule, which was originally prompted by the June 2017 Treasury Report that solicited changes to ease the compliance burden on banks.  The NPR includes several changes
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