3checking account held by Wells Fargo Bank, N.A., which is a national bank and a U.S. insureddepository institution.
.Mr. Taylor and Ms. Ekman are members of Occupy the SEC, a subgroup of the OccupyWall Street movement and an unincorporated association that advocates for regulatory reforms inthe banking and financial system.
. at ¶¶ 5, 6. OSEC has been recognized internationally as anauthoritative voice on the Volcker Rule. Taylor Decl. ¶ 8. OSEC’s advocacy on the Rule hasincluded meetings with hundreds of Congressional staffers and regulatory officials from each of the five Agencies in charge of writing the Rule, op-ed articles, press releases, and close to onehundred interviews with domestic and international media outlets.
. OSEC submitted a 325- page comment letter in February 2012 in response to the Proposed Rule promulgated by the fiveAgencies responsible for the Volcker Rule rulemaking.
. ¶ 7. This comment letter has been praised as “powerful” by the N.Y. Times, “amazing” by Reuters, and an “intelligent, sober response to a serious issue” by Time Magazine.
B. Background on the Volcker Rule
The Volcker Rule generally prohibits banking entities from engaging in proprietarytrading and from maintaining certain relationships with hedge funds or private equityfunds. 12 U.S.C. § 1851. It was passed to help avert another global financial crisis, byrestraining the type of high-risk proprietary trading that can undermine insured depositoryinstitutions.
156 Cong. Rec. S5894 (daily ed. July 15, 2010) (statement of Sen. Merkley).The Glass-Steagall Act of 1933 protected bank depositors from market fluctuations by prohibiting retail banks from engaging in most trading activities. Am. Compl. ¶ 13. That lawgenerally required a structural separation of retail banks from investment banks.
. TheFinancial Services Modernization Act of 1999 repealed parts of the Glass-Steagall Act, allowing