It's a good thing the unofficial 'Comment Period" remains open because a lot more people have things to say about the controversial Volcker Rule.  Take today's comments from a Federal Reserve Bank president - Jeffrey Lacker, who runs the Reserve Bank in Richmond. He said that a U.S. law restricting proprietary trading at banks and scheduled for enactment in July may be "impossible" to implement.  [C-I Note: Well phrased, Jeff.] The Volcker rule is "fairly difficult if not impossible to implement in a way that is at all reasonable," Mr. Lacker said during a Bloomberg interview.  The proposal is one of the most contentious provisions of the 2010 Dodd-Frank act on financial oversight, and Lacker said it would be "high on the list" of things he would change if he could. Work on the rule is diverting resources from more "essential" requirements in the act that would limit taxpayer-funded bailouts, such as living wills where large banks must describe to regulators how they would dissolve themselves in a crisis, he said. "We need to push hard to have firms structure themselves, restructure themselves if necessary, to make sure" their resolution "is an orderly process," Mr. Lacker said.  "Working through that will reveal a lot about what authorities should be afraid of or not afraid of about sending a large institution to bankruptcy without U.S. government assistance." "The goal, I think, ought to be no taxpayer assistance for failing institutions," he Lacker said. Second Largest The Richmond Fed has supervisory responsibility for Bank of America Corp., the second-largest U.S. bank by assets. Fed Chairman Ben S. Bernanke said on 2/29/12 that the central bank and other regulators won’t meet the July deadline to complete work on the Volcker rule.  The Fed has received over 17,000 comment letters on the proposal. The ban on proprietary trading is set to take effect by 7/21/12 - a deadline that remains unchanged -  even if the rule-making is still in progress.  It would include a 2-year transition period.  The Fed then could issue three 1-year implementation extensions on a case-by-case basis after that. Regulators, including Fed Governor Daniel Tarullo, said at a 3/22/12 Senate Banking Committee hearing that they could provide guidance on the conformance period of the Volcker rule if the July deadline isn’t met. "It’s incumbent on all the regulators to provide some guidance for firms to let them know exactly what the expectations will be, and not let this hang out there as an unknown," Mr. Tarullo said. Former Federal Deposit Insurance Corp. Chairman Sheila Bair has told lawmakers that the Volcker rule is so complicated that regulators should consider starting over. Representative Barney Frank, a Democrat from Massachusetts and co-author of the Dodd-Frank act, issued a statement last month urging regulators to release a simplified version of the proprietary trading ban by 9/3/12. Click to access referenced story:  [Bloomberg, 4/4/12].