Response to Notice of Proposed Rulemaking: Restrictions on Proprietary Trading and Certain Interests

In response to the Notice of Proposed Rulemaking, Restrictions on Proprietary Trading and Certain Interests in and Relationships with Hedge Funds and Private Equity, ITIF urges the Agencies to carefully consider the ramifications of their actions as they adopt final rules in this proceeding. Specifically, ITIF believes that the Agencies should implement the Volcker Rule so that it affects the two types of funds referred to explicitly by Congress - private equity funds and hedge funds ­and does not sweep in other activities that do not present the type of risk Congress sought to regulate. In particular, ITIF urges the Agencies not to apply the Volcker Rule to venture capital funds and investments.