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Volcker 2.0 and the RENTD Requirement...What's Changed?

6/28/2018  ·  by Deloitte  ·  Volcker Rule  ·  Research and Background Documents

In 2017, Deloitte published “RENTD: The heart of the Volcker Rule”,1 which provided a comprehensive perspective on the RENTD regulatory construct and approaches to complying with this requirement. As the Agencies have now published proposed revisions2 to the final implementing regulations3, much attention has been directed toward understanding the implications of the new proposal and chief among them is the RENTD requirement.4 Initial coverage of the proposed revisions focused on the increased flexibility and ease of compliance offered by the replacement of the demonstrable analysis standard with a risk-limit based presumption of compliance

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