The Securities and Exchange Commission (“SEC”), the Department of the Treasury, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation (collectively, the “Regulators”) published regulatory proposals and questions regarding implementation of the so-called “Volcker Rule” from section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The proposals sought to prevent banks, their holding companies and any affiliates from engaging in proprietary trading and making direct and significant investments in hedge funds and private equity funds. The proposals included exemptions to permit market making but under tight restrictions.