The Office of the Comptroller of the Currency, or OCC, has issued a short bulletin on compliance with the Volcker Rule. While largely a short restatement of the rule, it contains this note for community banks:
Banks that do not engage in covered activities or investments are not required to establish a compliance program under the final regulations. This exemption extends to trading activities in certain exempt government and municipal obligations. Smaller banks, with total consolidated assets of $10 billion or less, engaged in modest proprietary trading activities for their own accounts are subject to a simplified compliance program. These banks may satisfy their compliance obligations under the final regulations by including in their existing policies and procedures appropriate references to the requirements of the final regulations. These policies and procedures should be appropriate to the size, scope, and complexity of the banks.
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