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The OCC estimates that the costs associated with the Dodd-Frank propriety trading rule known as the Volcker Rule will range from $412 million to $4.3 billion. The OCC estimates that 46 OCC-supervised banks with over $10 billion in assets will be required to report metrics and establish an enhanced compliance program, or establish a core compliance program. Of these 46, the OCC estimated that the compliance costs in 2014 will be $402 million for the seven large market-making banks and $0 for the other 39 banks. In 2015, the seven large banks are expected to spend $365 million on compliance costs and the other 39 banks are estimated to spend $176 million. Costs are estimated to remain close to 2015-levels for the following two years.

In addition, the OCC reports that the final rule will have a significant economic impact on seven small banks. The economic impact is significant if the total costs in a single year are greater than 5% of total salaries and benefits, or greater than 2.5% of total noninterest expense.


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