OCC seeks renewal of reporting and recordkeeping rules for proprietary trading and covered funds
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This notice asks the public to comment on the OCC’s request to renew an existing paperwork collection tied to the Volcker Rule. It does not change the rule itself. Banks and other for-profit banking entities that trade for themselves or have certain ties to hedge funds and private equity funds are the main parties affected, because they must keep records, file metrics in some cases, provide disclosures, and maintain compliance programs. The practical issue is administrative burden. The OCC says the collection helps it monitor compliance with limits on proprietary trading and covered fund relationships, and it estimates 39 respondents and 20,410 total annual burden hours. Comments are due by June 1, 2026, and firms can also use the comment process to challenge the burden estimate or suggest ways to simplify reporting.
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Key Changes
- No new rule change; the OCC is renewing an existing information collection tied to Volcker Rule compliance.
- Banks subject to the rule may need to keep records, report trading metrics, provide investor disclosures, and maintain compliance documentation.
- The notice opens a public comment period on the need for the collection, its burden estimate, and ways to reduce reporting costs.
Obligations
What this law requires
Banking entities that rely on the market-making presumption of compliance must make available to the OCC, upon request, records of any limit that is exceeded and any temporary or permanent increase to limits, in the form and manner directed by the OCC.
Banking entities covered by the Volcker Rule must maintain records sufficient to demonstrate compliance with section 13 of the BHC Act and 12 CFR part 44, promptly provide those records to the OCC upon request, and retain them for at least 5 years unless the OCC requires a longer period.
Banking entities with significant trading assets and liabilities must maintain a compliance program that includes records sufficient to demonstrate compliance with section 13 of the BHC Act and 12 CFR part 44, and must promptly provide those records to the OCC upon request.
Banking entities with significant trading assets and liabilities must file a CEO attestation.
Banking entities with significant trading assets and liabilities must maintain a compliance program with records sufficient to demonstrate compliance with section 13 of the BHC Act and 12 CFR part 44, promptly provide those records to the OCC upon request, and retain them for at least 5 years unless the OCC requires a longer period.