In jest, I wrote that we should occupy the SEC, but noted that they are very open to comments and influence by the public. One of the comments to that story was from a group organized as Occupy the SEC and they were planning to comment on the Volker Rule.
They submitted a massive comment letter attacking not only the proposed regulation. It is a 325 manifesto.
“We believe the Volcker Rule is important to the future of the banking industry and, if strongly enforced, will help move our financial system in a more fair, transparent, and sustainable direction. Prohibiting banking entities from engaging in proprietary trading and banning their sponsorship of covered funds are key elements to regulating the financial system and giving force to the Dodd-Frank Act. At its core, the Volcker Rule seeks to make sure that if a banking entity fails, it does not bring down the whole system with it. We appreciate the momentous challenges that the Agencies continue to face in effectively implementing the Rule, and we present these comments to assist them in their task.”
Like most commenters, and even Mr. Volker himself, Occupy the SEC labels the proposal a “500-page web of complexity”. But rather than complain and make some generic statements, Occupy SEC provides very detailed comments on the text of the rule, specific textual changes to the regulation, and answers to hundred of the questions presented in the proposed rule.
From the perspective of private equity funds, Occupy the SEC wants to make sure the rule is broad enough to cover a broad scope of entities by making some changes to the definition of “covered fund” and “ownership interest”.
The comment letter is an impressive piece of work.