PwC's Managing upstream risk: Regulatory reform review - An asian perspective December 2013 | Page 15

2.2 Dodd-Frank Act Excerpt from PwC’s regulatory brief – “Volcker Shrugged” The most eagerly awaited final rule in the history of financial regulation was delivered last week – 1,238 days since it became law and 764 days since being formally issued in proposed form. Was the final Volcker rule worth the wait? For foreign banks and custody banks, the answer is clearly yes. The expansion of the SOTUS exemption and the narrowing of the covered fund definition from the original version of the rule gave those banks most of what they wanted.