The Volcker Rule prohibitions come into effect on July 21, 2012, regardless of whether the regulations are fi nal- ized by that point. 37 Banking entities have a further pe- riod of two years from the effective date to comply with the Volcker Rule. 38 Additionally, regulators may, upon application by any banking entity, extend the transition period for the requesting banking entity (i) for up to fi ve years (which is in addition to the two year transition pe- riod), 39 and (ii) to the “extent necessary to fulfi ll a contrac- tual obligation that was in effect on May 1, 2010” to.
