Section 619 of Dodd-Frank (the “Volcker Rule”) generally prohibits any banking entity, including affi liates of banks, from the following (all of which are subject to a number of exceptions): (i) engaging in, sponsoring or investing in a “covered fund” (., a hedge fund, pri- vate equity fund, and numerous other private funds and pooled investment vehicles), and (ii) having certain rela- tionships with a covered fund. 33 Additionally, the Volcker Rule places further restrictions on banking entities and their affi liates from serving as an investment adviser to a private fund. 34 The Volcker Rule also prohibits banking entities from engaging.
