Banking and Finance Law Daily Wrap Up, VOLCKER RULE—OCC seeks renewal of Volcker Rule recordkeeping information collection, (Feb 11, 2026)

By Colleen M. Svelnis, J.D.

The OCC plans no changes to its Volcker Rule recordkeeping and reporting requirements.

The Office of the Comptroller of the Currency has requested comment concerning the renewal of its information collection titled, “Reporting, Recordkeeping, and Disclosure Requirements Associated with Proprietary Trading and Certain Interests in and Relationships with Covered Funds.” The OCC states the submission “involves no change to the regulation or to the information collection requirements” and requests that the Office of Management and Budget (OMB) renew its approval. The notice is scheduled for publication in the Federal Register on Feb. 12, 2026. Comments are due by April 13.

Although the OCC states the renewal involves no changes to existing Volcker Rule information collection requirements, affected institutions should review current processes for metrics reporting, documentation, and CEO attestation to ensure timely compliance with ongoing obligations and to consider whether to submit feedback within the 60 day window.

Section 13 of the Bank Holding Company Act (added by section 619 of the Dodd-Frank Act) generally prohibits banking entities from proprietary trading and from certain covered fund activities, subject to exemptions. The OCC’s implementing rule became effective April 1, 2014. The collection supports compliance monitoring and enforcement of these requirements.

Comments submitted in response to the notice will be summarized and included in the request for OMB approval. All comments will become a matter of public record.

Comments are invited on the following:

• whether the collection of information is necessary for the proper performance of the functions of the OCC, including whether the information has practical utility;

• the accuracy of the OCC’s estimate of the burden of the collection of information;

• ways to enhance the quality, utility, and clarity of the information to be collected;

• ways to minimize the burden of the collection on respondents, including through the use of automated collection techniques or other forms of information technology; and

• estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information.

RegulatoryActivity: BankHolding BankingOperations DoddFrankAct GCNNews VolckerRule