Eminence submitted comments on April 1 in response to the proposed joint rulemaking by the SEC, CFTC, and banking regulators to amend certain aspects of the Volcker Rule. The letter expresses support for the proposal to exclude debt instruments that provide limited rights to participate in the removal of an asset manager in the event of default or an acceleration event from being treated as an equity like interest. The letter also expresses support the proposal to permit loan securitizations to hold a small amount of non-loan assets.
