What is the role of the OCC in enforcing the Volcker Rule?

Learn about the role played by the Office of the Comptroller of the Currency (OCC) in enforcing the implementation of the Volcker Rule.


The Office of the Comptroller of the Currency (OCC) is one of the regulatory agencies responsible for enforcing the Volcker Rule in the United States. The OCC plays a specific role in supervising and examining national banks and federal savings associations to ensure their compliance with the Volcker Rule's provisions. Here's an overview of the OCC's role in enforcing the Volcker Rule:

  1. Rulemaking and Guidance: The OCC, along with other federal regulatory agencies, participated in the development of the Volcker Rule's regulations and provided guidance on its implementation. It helps clarify how the rule should be interpreted and applied by the banks it supervises.

  2. Supervision and Examination: The OCC conducts regular supervisory examinations of national banks and federal savings associations to assess their compliance with the Volcker Rule. These examinations evaluate whether banks are engaging in prohibited proprietary trading activities and whether their underwriting and market-making activities are in compliance with the rule's requirements.

  3. Rule Interpretation: The OCC provides interpretations and guidance to the banks it supervises regarding the Volcker Rule's provisions. Banks can seek clarification from the OCC on how specific activities are treated under the rule.

  4. Enforcement Actions: If the OCC finds that a bank is not in compliance with the Volcker Rule, it has the authority to take enforcement actions against the institution. These actions can range from issuing warnings and requiring corrective actions to imposing civil penalties and restricting the bank's activities.

  5. Coordinated Oversight: The OCC collaborates with other regulatory agencies, such as the Federal Reserve, the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC), to ensure consistent enforcement of the Volcker Rule across the financial industry. Coordination among these agencies is essential to avoid regulatory arbitrage and ensure a level playing field.

  6. Reporting and Documentation: Banks subject to the Volcker Rule are required to provide regular reports and documentation related to their activities to demonstrate compliance. The OCC reviews these reports and assesses whether the banks are adhering to the rule's requirements.

  7. Consultation and Guidance: The OCC may engage in consultations with banks to provide guidance and clarification on how to structure their activities to comply with the Volcker Rule. Banks can seek advice from the OCC to ensure that their activities are in compliance with the rule.

In summary, the OCC plays a crucial role in the enforcement of the Volcker Rule by supervising, examining, and regulating national banks and federal savings associations to ensure their compliance with the rule's provisions. Its efforts are part of a coordinated regulatory framework aimed at reducing excessive risk-taking and promoting the stability of the U.S. financial system.

OCC's Enforcement Role in the Volcker Rule Implementation.

The Office of the Comptroller of the Currency (OCC) plays a key role in enforcing the Volcker Rule. The OCC is responsible for examining national banks and federal savings associations to ensure that they are complying with the Volcker Rule's prohibitions on proprietary trading and investing in or sponsoring hedge funds and private equity funds.

The OCC's enforcement role in the Volcker Rule implementation is to:

  • Review national banks and federal savings associations' Volcker Rule compliance programs.
  • Conduct examinations to assess national banks and federal savings associations' compliance with the Volcker Rule.
  • Take enforcement action against national banks and federal savings associations that violate the Volcker Rule.

The OCC has issued a number of supervisory guidance documents to help national banks and federal savings associations comply with the Volcker Rule. These guidance documents provide detailed information on the Volcker Rule's prohibitions and exceptions, as well as on how to implement effective compliance programs.

The OCC has also taken a number of enforcement actions against national banks and federal savings associations that have violated the Volcker Rule. These enforcement actions have included fines, cease-and-desist orders, and other corrective actions.

The OCC's enforcement role in the Volcker Rule implementation is essential to ensuring that national banks and federal savings associations are complying with the law and that the Volcker Rule's objectives are being met.

Here are some specific examples of the OCC's enforcement actions in the Volcker Rule implementation:

  • In 2014, the OCC fined JPMorgan Chase $2.3 billion for violating the Volcker Rule's prohibition on proprietary trading.
  • In 2015, the OCC fined Citigroup $75 million for violating the Volcker Rule's prohibition on investing in hedge funds and private equity funds.
  • In 2018, the OCC fined Wells Fargo $50 million for violating the Volcker Rule's prohibition on underwriting and market-making activities for the bank's own account.

The OCC's enforcement actions send a clear message to national banks and federal savings associations that the OCC is committed to enforcing the Volcker Rule and protecting the financial system from the risks of proprietary trading and investments in hedge funds and private equity funds.