The federal banking agencies and the SEC recently proposed regulations to implement Section 13 of the Bank Holding Company Act, also known as the Volcker Rule, adopted as part of the Dodd-Frank Act.  The Volcker Rule prohibits proprietary trading and private fund investments and sponsorship by banking entities, subject to certain exceptions.  In a guest article, Ropes & Gray LLP Partners Joel Wattenbarger, Jason E. Brown and Mark Nuccio, along with Ropes Associate Alyssa Clough, address the restrictions on investments into private funds and the effect they will have on private fund sponsors, highlight certain issues and potential structuring opportunities that are applicable to private fund sponsors and identify some issues that require further clarification.