1. The Business Model of Banking and how institutions will have to adapt themselves to the new regulatory environment
2. Investments in capital and human resources
3. Changes/improvements to the Banks’ technology capacity and structure
4. Business Profitability, Staff Compensation and Competitiveness
Compliance program requirements for the Volcker Rule of the Dodd-Frank ActGrant Thornton LLP
Regulatory requirements for both enhanced and standardized compliance programs as stipulated by the Volcker Rule of the Dodd-Frank Act.
Watch our webcast to learn more: http://gt-us.co/1FOw3XF
FinfraG: Opportunities & Challenges for Global Trading PlatformsCognizant
The Swiss Financial Market Infrastructure Act (FMIA), commonly known by its German name, FinfraG, spells out regulations for global derivative trading platforms and central clearing parties, including reporting, clearing, platform trading and risk mitigation. The act also incorporates laws pertaining to insider information/market abuse and shareholdings/public offers.
Compliance program requirements for the Volcker Rule of the Dodd-Frank ActGrant Thornton LLP
Regulatory requirements for both enhanced and standardized compliance programs as stipulated by the Volcker Rule of the Dodd-Frank Act.
Watch our webcast to learn more: http://gt-us.co/1FOw3XF
FinfraG: Opportunities & Challenges for Global Trading PlatformsCognizant
The Swiss Financial Market Infrastructure Act (FMIA), commonly known by its German name, FinfraG, spells out regulations for global derivative trading platforms and central clearing parties, including reporting, clearing, platform trading and risk mitigation. The act also incorporates laws pertaining to insider information/market abuse and shareholdings/public offers.
Operational risk management and measurementRahmat Mulyana
a short description in mixed English and Bahasa Indonesia on Operational Risk Management and Measurement, in particular value at risk calculation using Monte carlo Simulation. Another method using EVT (Extree Value Theory) will be delivered shortly. regards
Operational Risk Management under BASEL eraTreat Risk
Operational risk have always ignored by Banks as they thought Credit and market risks can cause catastrophe. But history of misfortunes taught us different lessons. Controls and internal audit have long been construed as guard till BASEL II dictates forced banks to look with insight. Understand the dimension of ORM in this presentation.
Building out a Robust and Efficient Risk Management - Alan CheungLászló Árvai
Credit Derivatives are off-balance sheet financial statements that permit one party to transfer the risk of a reference asset, which it typically owns, to another one party (the guarantor) without actually selling the assets.
Volcker Rule Compliance: Preparing for the Long Haul Cognizant
For financial institutions, compliance with the Dodd-Frank Volcker Rule is a matter of urgency, and we provide a roadmap for preparation, analysis, and implementation with respect to systemic risk management, market making, underwriting, hedging, avoidance of proprietary trading, reporting infrastructures and more.
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
Operational Risk Management Under Basel II & Basel IIIEneni Oduwole
In this introductory presentation on the subject, salient features that changed in approaches adopted for Operational Risk Management under Basel I and Basel I were highlighted.
Third-Party Risk Management: A Case Study in OversightNICSA
Two Part Series: Part II of II
Third-Party Risk Management: A Case Study in Oversight
Sleep Better at Night: Learn techniques to manage risks associated with third-party relationships.
Risk management is an integral part of business management. This set of principles was developed by the industry for the industry. They have been drafted to make them so practical that they will resonate with any financial organization.
Webinar – Pricing & Regulations: Will you be able to justify your valuations ...aimsoftware
Webinar – Pricing & Regulations: Will you be able to justify your valuations when the regulator comes calling?
For Asset Managers, Shadow Banking and the means to be able to monitor more accurately the quality of service being provided by your Third Party Administrator is growing in importance, combined with regulatory topics such as EMIR and changes in CCP clearing.
For Fund Accounting and Administration service providers serving this community, the imminent arrival of market infrastructure changes such as T2S and CSDR, means the need to be operationally efficient and adaptable to change becomes ever more important. Market reputation is also an increasing focus and worry, plus competitive edge.
This webinar looks at the requirements of both communities and explores what practitioners should be doing to meet the imminent arrival of shadow banking regulations and market infrastructure changes.
Topics include:
• Case study of European Fund Administration, presented by M. Verdure, CIO of EFA
• A short live demonstration of GAIN Portfolio Pricing
Speakers:
• Jean-Marc Verdure, CIO and Director of Organization, European Fund Administration
• Olivier Kenji Mathurin, Head of Product Marketing and AIM Research Lab, AIM Software
Date: Tuesday 17th June, 2014
RECORDED SESSION: http://www.aimsoftware.com/news/webinar-pricing-regulations-now-available-on-demand
The factsheet provides a concise description of the function and benefits of managed futures, while also explaining some of the key differences between public and private pools. This resource explains the purpose of managed futures, their role for investors, how they are regulated, and what fees are charged and disclosed to investors.
Risk assessment and management seminar presented 18 March 2015 for Nepali bankers and government officials. Basel III compliance issues addressed with recent examples from Thailand, US, and Nepal.
Operational risk management and measurementRahmat Mulyana
a short description in mixed English and Bahasa Indonesia on Operational Risk Management and Measurement, in particular value at risk calculation using Monte carlo Simulation. Another method using EVT (Extree Value Theory) will be delivered shortly. regards
Operational Risk Management under BASEL eraTreat Risk
Operational risk have always ignored by Banks as they thought Credit and market risks can cause catastrophe. But history of misfortunes taught us different lessons. Controls and internal audit have long been construed as guard till BASEL II dictates forced banks to look with insight. Understand the dimension of ORM in this presentation.
Building out a Robust and Efficient Risk Management - Alan CheungLászló Árvai
Credit Derivatives are off-balance sheet financial statements that permit one party to transfer the risk of a reference asset, which it typically owns, to another one party (the guarantor) without actually selling the assets.
Volcker Rule Compliance: Preparing for the Long Haul Cognizant
For financial institutions, compliance with the Dodd-Frank Volcker Rule is a matter of urgency, and we provide a roadmap for preparation, analysis, and implementation with respect to systemic risk management, market making, underwriting, hedging, avoidance of proprietary trading, reporting infrastructures and more.
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
Operational Risk Management Under Basel II & Basel IIIEneni Oduwole
In this introductory presentation on the subject, salient features that changed in approaches adopted for Operational Risk Management under Basel I and Basel I were highlighted.
Third-Party Risk Management: A Case Study in OversightNICSA
Two Part Series: Part II of II
Third-Party Risk Management: A Case Study in Oversight
Sleep Better at Night: Learn techniques to manage risks associated with third-party relationships.
Risk management is an integral part of business management. This set of principles was developed by the industry for the industry. They have been drafted to make them so practical that they will resonate with any financial organization.
Webinar – Pricing & Regulations: Will you be able to justify your valuations ...aimsoftware
Webinar – Pricing & Regulations: Will you be able to justify your valuations when the regulator comes calling?
For Asset Managers, Shadow Banking and the means to be able to monitor more accurately the quality of service being provided by your Third Party Administrator is growing in importance, combined with regulatory topics such as EMIR and changes in CCP clearing.
For Fund Accounting and Administration service providers serving this community, the imminent arrival of market infrastructure changes such as T2S and CSDR, means the need to be operationally efficient and adaptable to change becomes ever more important. Market reputation is also an increasing focus and worry, plus competitive edge.
This webinar looks at the requirements of both communities and explores what practitioners should be doing to meet the imminent arrival of shadow banking regulations and market infrastructure changes.
Topics include:
• Case study of European Fund Administration, presented by M. Verdure, CIO of EFA
• A short live demonstration of GAIN Portfolio Pricing
Speakers:
• Jean-Marc Verdure, CIO and Director of Organization, European Fund Administration
• Olivier Kenji Mathurin, Head of Product Marketing and AIM Research Lab, AIM Software
Date: Tuesday 17th June, 2014
RECORDED SESSION: http://www.aimsoftware.com/news/webinar-pricing-regulations-now-available-on-demand
The factsheet provides a concise description of the function and benefits of managed futures, while also explaining some of the key differences between public and private pools. This resource explains the purpose of managed futures, their role for investors, how they are regulated, and what fees are charged and disclosed to investors.
Risk assessment and management seminar presented 18 March 2015 for Nepali bankers and government officials. Basel III compliance issues addressed with recent examples from Thailand, US, and Nepal.
Evolution of Clinical Alarms and Text Messaging in Healthcare CommunicationsExtension Healthcare
Patient monitor alarms are successful at increasing nurse response times and credited with saving lives. They have quickly proliferated and joined with various other medical devices, nurse call systems, and clinical information systems to generate noise and interrupt nurses performing direct care tasks. The Extension Engage™ alarm management and event response platform aids nurses in organizing and prioritizing the alarms, alerts, and text messages competing for attention.
The Volcker Rule, a part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, was adopted on December 10, 2013. Check out how CH&Cie can help your organization implement it
Conduct risk beyond the rulebook bovill briefing march 2014Bovill
Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the March briefing on Conduct Risk. For more information visit www.bovill.com.
Further information on the event is below:
Conduct Risk: beyond the rule book
“One of the features of regulation, historically, was that it was all about compliance. Were a particular set of rules followed? Could a firm demonstrate and document that it had followed those rules to the letter? This created a cottage industry out of compliance – but did not necessarily lead to good outcomes…””
Martin Wheatley, CEO, Financial Conduct Authority
The FCA rulebook still matters, as any firm who has had a brush with the rules on client money and assets will know. However, the financial crisis showed that traditional compliance can mean the firm only knows what went wrong yesterday. Understanding what might happen tomorrow is equally important.
Managing Conduct Risk is now a key FCA expectation. It involves understanding what outcomes will flow from today’s actions – for the firm, its customers and the financial markets more broadly. And the Conduct Risk agenda is now more likely to involve smaller firms.
Bovill’s briefing looked at Conduct Risk and covered:
• What is Conduct Risk and where did the idea come from?
• What regulatory powers does the FCA use in its approach?
• How can you manage Conduct Risk?
How to Drive Value from Operational Risk Data - Part 2Perficient, Inc.
As complexities in the financial markets continue to increase, so too does the challenge of understanding and mitigating operational risks that can negatively affect the business. Many firms still struggle with risk identification and how data can be leveraged across the enterprise to prevent operational risk losses and gain operational efficiencies.
During this webinar, Perficient’s industry experts discussed the evolving role and challenges of operational risk management (ORM) in financial services, tips for a comprehensive approach to identify, assess and mitigate risks, and strategies to gain value from operational risk data to support the business.
Forward-Looking Practices in Wealth ManagementCognizant
To keep up with growing regulations in wealth management sector, firms need to future-proof their operations with a robust risk-control system and transparent trading practices.
The SEC & FINRA released their priorities for 2016 examinations. Asset management firms need to review + update their policies, procedures and business activities to reflect both sets of priorities so they can strengthen business practices and prepare for potential exams.
Similar to Volcker Rule Challenges for Covered Banking Entities (20)
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
what is the future of Pi Network currency.DOT TECH
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
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Contact with Dawood Bhai Just call on +92322-6382012 and we'll help you. We'll solve all your problems within 12 to 24 hours and with 101% guarantee and with astrology systematic. If you want to take any personal or professional advice then also you can call us on +92322-6382012 , ONLINE LOVE PROBLEM & Other all types of Daily Life Problem's.Then CALL or WHATSAPP us on +92322-6382012 and Get all these problems solutions here by Amil Baba DAWOOD BANGALI
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how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
What price will pi network be listed on exchangesDOT TECH
The rate at which pi will be listed is practically unknown. But due to speculations surrounding it the predicted rate is tends to be from 30$ — 50$.
So if you are interested in selling your pi network coins at a high rate tho. Or you can't wait till the mainnet launch in 2026. You can easily trade your pi coins with a merchant.
A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the telegram contact of my personal pi vendor to trade with.
@Pi_vendor_247
Currently pi network is not tradable on binance or any other exchange because we are still in the enclosed mainnet.
Right now the only way to sell pi coins is by trading with a verified merchant.
What is a pi merchant?
A pi merchant is someone verified by pi network team and allowed to barter pi coins for goods and services.
Since pi network is not doing any pre-sale The only way exchanges like binance/huobi or crypto whales can get pi is by buying from miners. And a merchant stands in between the exchanges and the miners.
I will leave the telegram contact of my personal pi merchant. I and my friends has traded more than 6000pi coins successfully
Tele-gram
@Pi_vendor_247
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Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
what is the best method to sell pi coins in 2024DOT TECH
The best way to sell your pi coins safely is trading with an exchange..but since pi is not launched in any exchange, and second option is through a VERIFIED pi merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and pioneers and resell them to Investors looking forward to hold massive amounts before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade pi coins with.
@Pi_vendor_247
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
The secret way to sell pi coins effortlessly.DOT TECH
Well as we all know pi isn't launched yet. But you can still sell your pi coins effortlessly because some whales in China are interested in holding massive pi coins. And they are willing to pay good money for it. If you are interested in selling I will leave a contact for you. Just telegram this number below. I sold about 3000 pi coins to him and he paid me immediately.
Telegram: @Pi_vendor_247
Volcker Rule Challenges for Covered Banking Entities
1. THE VOLCKER RULE AND THE CHALLENGES AHEAD
BY OSCAR VANEGAS - SENIOR REGULATORY AND COMPLIANCE CONSULTANT
1
2. BACKGROUND
2
• The Volker Rule was constituted as section 619 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act
• Final ruling was implemented on December 10th, 2013 by five federal agencies –
the Federal Reserve, the Office of the Comptroller of the Currency (OCC), the
Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange
Commission (SEC) and the Commodity Future Trading Commission (CFTC)
• In its core principle, the rule was implemented to promote and enhance the safety
and soundness of banking entities; protect taxpayers and consumers and promote
financial stability by minimizing the risk associated with unsafe and unsound
activities
• The rule introduces a tiered compliance program that requires enhanced
processes and controls; banks with the largest trading businesses have began
reporting quantitative measurements on June 30, 2014 and bring trading activities
into full compliance by July 21, 2015
3. OVERVIEW
3
• The rule is intended to reduce the risks associated with short-term proprietary trading and limits
investment activities in covered funds, prohibiting the acquisition and retention of any equity,
partnership, or other ownership interest in or sponsor a hedge fund or a private equity fund
• What is proprietary trading? - engaging as a principal for the trading account of the banking
entity in any purchase or sale of one or more financial instruments
• What is “sponsoring”? - generally serving as GP, managing member or trustee, electing or
controlling majority of directors, trustees or management of fund sharing name with the
covered fund
• The final rule includes critical refinements that reduces the threat to market liquidity, trading
revenues, and the safety and soundness of the covered banking entities and other
systematically important financial institutions (SIFI)
• Coverage of activities conducted within the limits of the United States and its affiliated territories
• Coverage of transactions performed by foreign banking agencies that derived a considerably
portion of their profits while being conducted within the limits of the United Sates, or that such
covered transactions involve the participation therein of a U.S Citizen
4. CHALLENGES - THE BUSINESS MODEL
4
Covered Activities –
Business Model Re-
design
The core principles affected: investment
compliance, funding through market-making and
profitability of proprietary trading activities
• Maintain a very limited inventory Bank
customers will have lower market liquidity for
their securities higher financing costs
diminishing credit access
• Reduction in market making will obstruct the
ability to determine the quality of securitized
loans and the offering of credit facilities
New operational and risk management conditions:
identify transactions where the institution is taking
principal market risk from speculative proprietary
trading or investment risk – risk metrics and
reporting at the trading desk level
5. CHALLENGES – COMMITMENT IN CAPITAL INVESTMENTS AND
RESOURCES
5
Considerable efforts in
Capital Investment,
Human Capital and
Resources
• Design and implement an enhanced
compliance program
• Risk Metrics and Reporting
• Auditing activities and training of trading
personnel
• Reassessment of liquidity, market and
counterparty risk models enhanced capital
requirements Base III and CCAR
• Mitigate exposure to illiquid markets in
“stressed” conditions considerable swings
in volatilities in the markets
• dramatic changes in portfolio Value-at-Risk
measurements
Identification and Controls of covered activities:
• Serving as market makers and underwriters
only to meet the near term demands of
customers
• Standing ready to cover an incomplete side of a
trade
• Hurdles to arbitrage trading activities that
promote liquidity or price transparency
6. CHALLENGES – TECHNOLOGICAL CAPACITY AND STRUCTURE
6
Enhanced data provisioning
and market intelligence
systems
Identification, segregation and
delivering at the transactional
level
(including non-U.S txns)
Enhanced
Technological
Structure
Revamped
Technical
Capacity
Consolidate data
warehousing
Top-of-the-line transactional
data systems
Audit trials across multiple
trading desks
Consolidation of KRI and
metrics
Risk Management models
Validation
Advanced regulatory and
management reporting
Trading desks’ transactional
volume and income
generation
Trading personnel training
and systems’ support
7. CHALLENGES – BUSINESS PROFITABILITY, STAFF COMPENSATION AND
COMPETITIVENESS
7
Consolidate data
warehousing
Top-of-the-line transactional
data systems
Audit trials across multiple
trading desks
Consolidation of KRI and
metrics
Risk Management models
Validation
Advanced regulatory and
management reporting
Trading desks’ transactional
volume and income
generation
Trading personnel training
and systems’ support
• Minimum scope to profit from products’ inventories (market-
maker inventory is designed not to exceed the reasonably
expected near term demands of clients)
• Limited opportunities to profit from market movements and
volatilities
• Potential losses through incomplete trades
Business
Profitability
• Compensation schemes focused on trading volumes as
opposed to the more attractive profitability of the institution’s
own trading books
• Losing talented traders to the non-regulated hedge fund
industry
Compensatio
n
• Reduced global trading market restricted by extraterritorial
reach
• Restrictions to participate in OTC markets
• Considerable investments in technology, systems, audits,
controls and enhanced compliance programs
• Funding of investment vehicles going to unregulated markets
Competitivenes
s
8. COMPLIANCE PROGRAM – ILLUSTRATIVE STRUCTURE OF THE ENHANCED
COMPLIANCE PROGRAM
8
Governance
Senior Management CEO Board of Directors
• Approve, implement & enforce
• Periodic review for effectiveness
• Remediation and Board reporting
• Attestation that processes are in place
to ensure compliance with final rule
• Establish culture of compliance
• Supervise senior management team
• Align resources & incentives
• Approve program
Risk Management Analytics & Reporting Legal and Compliance
• Risk limit framework
• Robust analytics to set risk limits
• Model validation & documentation
• Exception policy (and monitoring)
• Escalation procedures
• Production & monitoring of metrics
• Robust analytics to set thresholds
• Exception policy (and monitoring)
• Escalation procedures
• Reporting
• Training
• Recordkeeping
• Conflicts of interest
• Remediation
Front Office Controls
• Define mission (i.e. trading activity) and strategy (i.e. trading method) for each trading desk
• Define authorized activities, products, and counterparties for each trading desk
• Policies and procedures for establishing limits, measuring activity, and enforcing compliance
• Policies and procedures for compensation, limiting incentives for prohibited proprietary trading or excessive risk taking
Independent Testing, Auditing and Staff Training
9. COMPLIANCE PROGRAM DESCRIPTION
9
INTERNAL POLICIES AND PROCEDURES: written policies and procedures reasonably
designed to document, describe, monitor and limit exempted trading activities conducted
by the banking entity
INTERNAL CONTROLS & MANAGEMENT FRAMEWORK—RESPONSIBILITYAND
ACCOUNTABILITY that clearly delineates responsibility and accountability; includes
appropriate review of trading limits, strategies, hedging activities, investments, incentive
compensation
INDEPENDENT TESTING and internal audit of the effectiveness of the compliance
program conducted periodically by qualified personnel of the banking entity or by a
qualified outside party
TRAINING for trading staff and managers, as well as other appropriate personnel, to
effectively implement and enforce the compliance program.
RECORDKEEPING sufficient to demonstrate compliance, which a banking entity must
promptly provide to regulators upon request and retain for a period of no fewer than 5
years. This must include records in connection with risk-mitigating hedging, underwriting
and market making permitted activities
10. REPORTING METRICS
10
Consolidate data
warehousing
Top-of-the-line transactional
data systems
Audit trials across multiple
trading desks
Consolidation of KRI and
metrics
Risk Management models
Validation
Advanced regulatory and
management reporting
Trading desks’ transactional
volume and income
generation
Trading personnel training
and systems’ support
• Risk and Position Limits and Usage
• Risk Factor Sensitivities
• Value at Risk (VaR) and Stress Value at Risk (Stress
VaR)
Risk Management
• Comprehensive Profit and Loss AttributionSource of Revenue
• Inventory Turnover
• Inventory Aging
• Customer-Facing Trade Ratio – Trade Count Based
and Value Based
Customer-Facing
Activity
11. CONCLUDING OBSERVATIONS
11
Consolidate data
warehousing
Top-of-the-line transactional
data systems
Audit trials across multiple
trading desks
• Increased market volatility, price uncertainty and the reduced capacity for
institutions to raise capital and/or hedge risk
• Impaired U.S. competitiveness, and potential vulnerability to legal challenges,
given the rule’s global scope of prohibitions
• Vulnerabilities around liquity, credit availability, funding and market & investment
risks
• Dedicate a considerable portion of their capital investments and resources to
address and implement all required elements in the final rule
• Compromise time and resources to coordinated several tasks with deferent
objectives between business strategy, compliance, finance and technology
• Business units consultative support is critical to implement a firm-wide Volcker
framework to ensure the complete validation and attestation of the covered
baking entities’ trading and fund investment businesses with the compliance
controls set-forth by the federal agencies.
13. KEY PROCEDURES AND LOGISTICS
13
Reporting Required / Optional
Reporting Required: metrics in respect of trading conducted
pursuant to the underwriting-related, market making-related,
risk-mitigating hedging and U.S./foreign government obligation
permitted activities
Reporting optional: metrics in respect of trading excluded from
the scope of proprietary trading, on behalf of customers,
regulated insurance company or foreign bank permitted
activities
Level of Measurement
Metrics reporting at the single trading desk level; each trading
desk, defined as the smallest discrete unit that purchases or
sells financial instruments for the trading account of the
banking entity or an affiliate of the banking entity.
Regulatory Reporting Frequency
For banking entities with $50 billion or more in trading assets
and liabilities: for each calendar month, within 30 days of the
end of the relevant month (beginning with information for
January 2015, within 10 days of month end)
For other banking entities: for each calendar quarter, within 30
days of quarter end
Record Retention
5 years; records documenting preparation/content of reports
submitted
14. TIMING AND APPLICABILITY OF COMPLIANCE PROGRAM AND METRICS
REPORTING
14
STANDARD COMPLIANCE PROGRAM– NO METRICS for Banking entities with more than
$10 billion but less than $50 billion of total consolidated assets and less than $10 billion of
trading assets and liabilities Compliance required: July 21, 2015
ENHANCED COMPLIANCE PROGRAM– NO METRICS for Banking entities with $50 billion
or more of total consolidated assets but less than $10 billion of trading assets and liabilities.
Compliance required: July 21, 2015
• ENHANCED COMPLIANCE PROGRAM WITH METRICS for Banking entities with total
consolidated assets of $50 billion or more, enhanced program effective: July 21, 2015
• Phase-in for metrics reporting requirements for banking entities with $10 billion or more in
trading assets and liabilities:
• For those with trading assets and liabilities of $50 billion or more: metrics June 30, 2014
• For those with trading assets and liabilities of between $25 billion and $50 billion: metrics
April 30, 2016
• For those with trading assets and liabilities of between $10 billion and $25 billion metrics
December 31, 2016