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Noel Gruber on TruPS Investments and the Volcker Rule
The letter states that "Your joint report 'The Volcker Rule: Community Bank Applicability' dated December 10, 2013 (the 'Community Bank Guide'), which accompanied the issuance of the final regulation implementing the Volcker Rule last week, has engendered hasty conclusions in the banking industry and among its advisors that all investments in collateralized debt obligations backed by trust preferred securities would be considered equity-like 'ownership interests' in a covered fund requiring divestiture by July 21, 2015" and asserts that "[i]t is essential that this week the agencies clarify the statement in the Community Bank Guide."