This is a reminder that, although an extension has been requested, the current deadline for submitting comments on the proposed regulations to implement the so-called Volcker Rule under the Dodd-Frank legislation is January 13, 2012, a date that is fast approaching.

The effort to coordinate the industry-wide response is being undertaken by SIFMA, but it is apparent that comments by individual firms, particularly investors, would be helpful to avoid what now appears to be the unintended consequence of an adverse effect on market liquidity due to the narrow exception for market-making under the general prohibition of proprietary trading.

Further information regarding this issue is contained in the links below, including contact information for the various regulatory bodies, as well as on the SIFMA website.

Further information regarding the proposed regulations is also available through Aviva Werner (

MMC article- Regulatory Threats to EM Debt Markets

Volcker Rule Outreach December 2011 vF3

EMTA Letter Requesting Extension of Comment Period under Volcker Rule

Volcker Extension Request 11-30-11

Barclays Structural Changes in IB 11-15-11