Til Finanstilsynet: Håper dere har lest dette, Volcker regelen er i gjære.

Jeg er litt sent ute på dette, beklager for alle dere finansfolk der ute. Volcker regelen er i gjære, regelen som sikre interne definisjoner og prosesser for ‘proprietary trading’ spesielt.

Den 11. oktober kommer FDIC (Federal Deposit Insurance Corp.) med sin 300+ siders rapport.

Allerede nå kan du smuglese rapporten. Notatene finner du her (pdf).

Ofte lekker slike utkast, spesielt noe så profilert og komplisert som dette.

La oss ta en titt:

In formulating the proposed rule, the Agencies have attempted to reflect the structure of section 13 of the BHC Act, which is to prohibit a banking entity from engaging in proprietary trading or acquiring or retaining an ownership interest in, or having certain relationships with, a covered fund, while permitting such entities to continue to provide client-oriented financial services.23 However, the delineation of what constitutes a prohibited or permitted activity under section 13 of the BHC Act often involves subtle distinctions that are difficult both to describe comprehensively within regulation and to evaluate in practice. The Agencies appreciate that while it is crucial that rules under section 13 of the BHC Act clearly define and implement its requirements, any rule must also preserve the ability of a banking entity to continue to structure its businesses and manage its risks in a safe and sound manner, as well as to effectively deliver to its clients the types of financial services that section 13 expressly protects and permits.

Løsningen på dette er tredelt:

  • (i) clearly describes the key characteristics of both prohibited and permitted activities;
  • (ii) requires banking entities to establish a comprehensive programmatic compliance regime designed to ensure compliance with the requirements of the statute and rule in a way that takes into account and reflects the unique nature of a banking entity’s businesses; and
  • (iii) with respect to proprietary trading, requires certain banking entities to calculate and report meaningful quantitative data that will assist both banking entities and the Agencies in identifying particular activity that warrants additional scrutiny to distinguish prohibited proprietary trading from otherwise permissible activities.

205 sider, enjoy!

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