Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Private Equity Funds, 5535-5806 [2013-31511]
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Vol. 79
Friday,
No. 21
January 31, 2014
Book 2 of 2 Books
Pages 5535–6076
Part II
Department of the Treasury
Office of the Comptroller of the Currency
Board of Governors of the Federal Reserve
System
Federal Deposit Insurance Corporation
Securities and Exchange Commission
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12 CFR Parts 44, 248, and 351
17 CFR Part 255
Prohibitions and Restrictions on Proprietary Trading and Certain Interests
in, and Relationships With, Hedge Funds and Private Equity Funds; Final
Rule
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
12 CFR Part 44
[Docket No. OCC–2011–0014]
RIN 1557–AD44
BOARD OF GOVERNORS OF THE
FEDERAL RESERVE SYSTEM
12 CFR Part 248
[Docket No. R–1432]
RIN 7100 AD82
FEDERAL DEPOSIT INSURANCE
CORPORATION
12 CFR Part 351
RIN 3064–AD85
SECURITIES AND EXCHANGE
COMMISSION
17 CFR Part 255
[Release No. BHCA–1; File No. S7–41–11]
RIN 3235–AL07
Prohibitions and Restrictions on
Proprietary Trading and Certain
Interests in, and Relationships With,
Hedge Funds and Private Equity Funds
Office of the Comptroller of the
Currency, Treasury (‘‘OCC’’); Board of
Governors of the Federal Reserve
System (‘‘Board’’); Federal Deposit
Insurance Corporation (‘‘FDIC’’); and
Securities and Exchange Commission
(‘‘SEC’’).
ACTION: Final rule.
AGENCY:
The OCC, Board, FDIC, and
SEC (individually, an ‘‘Agency,’’ and
collectively, ‘‘the Agencies’’) are
adopting a rule that would implement
section 13 of the BHC Act, which was
added by section 619 of the Dodd-Frank
Wall Street Reform and Consumer
Protection Act (‘‘Dodd-Frank Act’’).
Section 13 contains certain prohibitions
and restrictions on the ability of a
banking entity and nonbank financial
company supervised by the Board to
engage in proprietary trading and have
certain interests in, or relationships
with, a hedge fund or private equity
fund.
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SUMMARY:
The final rule is effective April
1, 2014.
FOR FURTHER INFORMATION CONTACT:
OCC: Ursula Pfeil, Counsel, or
Deborah Katz, Assistant Director,
Legislative and Regulatory Activities
DATES:
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Division, (202) 649–5490; Ted Dowd,
Assistant Director, or Roman Goldstein,
Senior Attorney, Securities and
Corporate Practices Division, (202) 649–
5510; Kurt Wilhelm, Director for
Financial Markets Group, (202) 649–
6360; Stephanie Boccio, Technical
Expert for Credit and Market Risk
Group, (202) 649–6360, Office of the
Comptroller of the Currency, 250 E
Street SW., Washington, DC 20219.
Board: Christopher M. Paridon,
Counsel, (202) 452–3274, or Anna M.
Harrington, Senior Attorney, Legal
Division, (202) 452–6406; Mark E. Van
Der Weide, Deputy Director, Division of
Bank Supervision and Regulation, (202)
452–2263; or Sean D. Campbell, Deputy
Associate Director, Division of Research
and Statistics, (202) 452–3760, Board of
Governors of the Federal Reserve
System, 20th and C Streets NW.,
Washington, DC 20551.
FDIC: Bobby R. Bean, Associate
Director, bbean@fdic.gov, or Karl R.
Reitz, Chief, Capital Markets Strategies
Section, kreitz@fdic.gov, Capital
Markets Branch, Division of Risk
Management Supervision, (202) 898–
6888; Michael B. Phillips, Counsel,
mphillips@fdic.gov, or Gregory S. Feder,
Counsel, gfeder@fdic.gov, Legal
Division, Federal Deposit Insurance
Corporation, 550 17th Street NW.,
Washington, DC 20429.
SEC: Josephine J. Tao, Assistant
Director, Angela R. Moudy, Branch
Chief, John Guidroz, Branch Chief,
Jennifer Palmer or Lisa Skrzycki,
Attorney Advisors, Office of Trading
Practices, Catherine McGuire, Counsel,
Division of Trading and Markets, (202)
551–5777; W. Danforth Townley,
Attorney Fellow, Jane H. Kim, Brian
McLaughlin Johnson or Marian Fowler,
Senior Counsels, Division of Investment
Management, (202) 551–6787; David
Beaning, Special Counsel, Office of
Structured Finance, Division of
Corporation Finance, (202) 551–3850;
John Cross, Office of Municipal
Securities, (202) 551–5680; or Adam
Yonce, Assistant Director, or Matthew
Kozora, Financial Economist, Division
of Economic and Risk Analysis, (202)
551–6600, U.S. Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Background
II. Notice of Proposed Rulemaking
III. Overview of Final Rule
A. General Approach and Summary of
Final Rule
B. Proprietary Trading Restrictions
C. Restrictions on Covered Fund Activities
and Investments
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D. Metrics Reporting Requirement
E. Compliance Program Requirement
IV. Final Rule
A. Subpart B—Proprietary Trading
Restrictions
1. Section ll.3: Prohibition on
Proprietary Trading and Related
Definitions
a. Definition of ‘‘Trading Account’’
b. Rebuttable Presumption for the ShortTerm Trading Account
c. Definition of ‘‘Financial Instrument’’
d. Proprietary Trading Exclusions
1. Repurchase and Reverse Repurchase
Arrangements and Securities Lending
2. Liquidity Management Activities
3. Transactions of Derivatives Clearing
Organizations and Clearing Agencies
4. Excluded Clearing-Related Activities of
Clearinghouse Members
5. Satisfying an Existing Delivery
Obligation
6. Satisfying an Obligation in Connection
With a Judicial, Administrative, SelfRegulatory Organization, or Arbitration
Proceeding
7. Acting Solely as Agent, Broker, or
Custodian
8. Purchases or Sales Through a Deferred
Compensation or Similar Plan
9. Collecting a Debt Previously Contracted
10. Other Requested Exclusions
2. Section ll.4(a): Underwriting
Exemption
a. Introduction
b. Overview
1. Proposed Underwriting Exemption
2. Comments on Proposed Underwriting
Exemption
3. Final Underwriting Exemption
c. Detailed Explanation of the
Underwriting Exemption
1. Acting as an Underwriter for a
Distribution of Securities
a. Proposed Requirements That the
Purchase or Sale Be Effected Solely in
Connection With a Distribution of
Securities for Which the Banking Entity
Acts as an Underwriter and That the
Covered Financial Position be a Security
i. Proposed Definition of ‘‘Distribution’’
ii. Proposed Definition of ‘‘Underwriter’’
iii. Proposed Requirement That the
Covered Financial Position Be a Security
b. Comments on the Proposed
Requirements That the Trade Be Effected
Solely in Connection With a Distribution
for Which the Banking Entity Is Acting
as an Underwriter and That the Covered
Financial Position Be a Security
i. Definition of ‘‘Distribution’’
ii. Definition of ‘‘Underwriter’’
iii. ‘‘Solely in Connection With’’ Standard
c. Final Requirement That the Banking
Entity Act as an Underwriter for a
Distribution of Securities and the
Trading Desk’s Underwriting Position Be
Related to Such Distribution
i. Definition of ‘‘Underwriting Position’’
ii. Definition of ‘‘Trading Desk’’
iii. Definition of ‘‘Distribution’’
iv. Definition of ‘‘Underwriter’’
v. Activities Conducted ‘‘in Connection
With’’ a Distribution
2. Near Term Customer Demand
Requirement
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a. Proposed Near Term Customer Demand
Requirement
b. Comments Regarding the Proposed Near
Term Customer Demand Requirement
c. Final Near Term Customer Demand
Requirement
3. Compliance Program Requirement
a. Proposed Compliance Program
Requirement
b. Comments on the Proposed Compliance
Program Requirement
c. Final Compliance Program Requirement
4. Compensation Requirement
a. Proposed Compensation Requirement
b. Comments on the Proposed
Compensation Requirement
c. Final Compensation Requirement
5. Registration Requirement
a. Proposed Registration Requirement
b. Comments on Proposed Registration
Requirement
c. Final Registration Requirement
6. Source of Revenue Requirement
a. Proposed Source of Revenue
Requirement
b. Comments on the Proposed Source of
Revenue Requirement
c. Final Rule’s Approach to Assessing
Source of Revenue
3. Section ll.4(b): Market-Making
Exemption
a. Introduction
b. Overview
1. Proposed Market-Making Exemption
2. Comments on the Proposed MarketMaking Exemption
a. Comments on the Overall Scope of the
Proposed Exemption
b. Comments Regarding the Potential
Market Impact of the Proposed
Exemption
3. Final Market-Making Exemption
c. Detailed Explanation of the MarketMaking Exemption
1. Requirement to Routinely Stand Ready
To Purchase And Sell
a. Proposed Requirement To Hold Self Out
b. Comments on the Proposed Requirement
To Hold Self Out
i. The Proposed Indicia
ii. Treatment of Block Positioning Activity
iii. Treatment of Anticipatory Market
Making
iv. High-Frequency Trading
c. Final Requirement To Routinely Stand
Ready To Purchase And Sell
i. Definition of ‘‘Trading Desk’’
ii. Definitions of ‘‘Financial Exposure’’ and
‘‘Market-Maker Inventory’’
iii. Routinely Standing Ready To Buy and
Sell
2. Near Term Customer Demand
Requirement
a. Proposed Near Term Customer Demand
Requirement
b. Comments Regarding the Proposed Near
Term Customer Demand Requirement
i. The Proposed Guidance for Determining
Compliance With the Near Term
Customer Demand Requirement
ii. Potential Inventory Restrictions and
Differences Across Asset Classes
iii. Predicting Near Term Customer
Demand
iv. Potential Definitions of ‘‘Client,’’
‘‘Customer,’’ or ‘‘Counterparty’’
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v. Interdealer Trading and Trading for
Price Discovery or To Test Market Depth
vi. Inventory Management
vii. Acting as an Authorized Participant or
Market Maker in Exchange-Traded
Funds
viii. Arbitrage or Other Activities That
Promote Price Transparency and
Liquidity
ix. Primary Dealer Activities
x. New or Bespoke Products or Customized
Hedging Contracts
c. Final Near Term Customer Demand
Requirement
i. Definition of ‘‘Client,’’ ‘‘Customer,’’ and
‘‘Counterparty’’
ii. Impact of the Liquidity, Maturity, and
Depth of the Market on the Analysis
iii. Demonstrable Analysis of Certain
Factors
iv. Relationship to Required Limits
3. Compliance Program Requirement
a. Proposed Compliance Program
Requirement
b. Comments on the Proposed Compliance
Program Requirement
c. Final Compliance Program Requirement
4. Market Making-Related Hedging
a. Proposed Treatment of Market MakingRelated Hedging
b. Comments on the Proposed Treatment of
Market Making-Related Hedging
c. Treatment of Market Making-Related
Hedging in the Final Rule
5. Compensation Requirement
a. Proposed Compensation Requirement
b. Comments Regarding the Proposed
Compensation Requirement
c. Final Compensation Requirement
6. Registration Requirement
a. Proposed Registration Requirement
b. Comments on the Proposed Registration
Requirement
c. Final Registration Requirement
7. Source of Revenue Analysis
a. Proposed Source of Revenue
Requirement
b. Comments Regarding the Proposed
Source of Revenue Requirement
i. Potential Restrictions on Inventory,
Increased Costs for customers, and Other
Changes To Market-Making Services
ii. Certain Price Appreciation-Related
Profits Are an Inevitable or Important
Component of Market Making
iii. Concerns Regarding the Workability of
the Proposed Standard in Certain
Markets or Asset Classes
iv. Suggested Modifications to the
Proposed Requirement
v. General Support for the Proposed
Requirement or for Placing Greater
Restrictions on a Market Maker’s Sources
of Revenue
c. Final Rule’s Approach To Assessing
Revenues
8. Appendix B of the Proposed Rule
a. Proposed Appendix B Requirement
b. Comments on Proposed Appendix B
c. Determination To Not Adopt Proposed
Appendix B
9. Use of Quantitative Measurements
4. Section ll.5: Permitted RiskMitigating Hedging Activities
a. Summary of Proposal’s Approach to
Implementing the Hedging Exemption
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b. Manner of Evaluating Compliance With
the Hedging Exemption
c. Comments on the Proposed Rule and
Approach to Implementing the Hedging
Exemption
d. Final Rule
1. Compliance Program Requirement
2. Hedging of Specific Risks and
Demonstrable Reduction Of Risk
3. Compensation
4. Documentation Requirement
5. Section ll.6(a)–(b): Permitted Trading
in Certain Government and Municipal
Obligations
a. Permitted Trading in U.S. Government
Obligations
b. Permitted Trading in Foreign
Government Obligations
c. Permitted Trading in Municipal
Securities
d. Determination To Not Exempt
Proprietary Trading in Multilateral
Development Bank Obligations
6. Section ll.6(c): Permitted Trading on
Behalf of Customers
a. Proposed Exemption for Trading on
Behalf of Customers
b. Comments on the Proposed Rule
c. Final Exemption for Trading on Behalf
of Customers
7. Section ll.6(d): Permitted Trading by
a Regulated Insurance Company
8. Section ll.6(e): Permitted Trading
Activities of a Foreign Banking Entity
a. Foreign Banking Entities Eligible for the
Exemption
b. Permitted Trading Activities of a Foreign
Banking Entity
9. Section ll.7: Limitations on Permitted
Trading Activities
a. Scope of ‘‘Material Conflict of Interest’’
1. Proposed Rule
2. Comments on the Proposed Limitation
on Material Conflicts of Interest
a. Disclosure
b. Information Barriers
3. Final Rule
b. Definition of ‘‘High-Risk Asset’’ and
‘‘High-Risk Trading Strategy’’
1. Proposed Rule
2. Comments on Proposed Limitations on
High-Risk Assets and Trading Strategies
3. Final Rule
c. Limitations on Permitted Activities That
Pose a Threat to Safety and Soundness
of the Banking Entity or the Financial
Stability of the United States
B. Subpart C—Covered Fund Activities and
Investments
1. Section ll.10: Prohibition on
Acquisition or Retention of Ownership
Interests in, and Certain Relationships
With, a Covered Fund
a. Prohibition Regarding Covered Fund
Activities and Investments
b. ‘‘Covered Fund’’ Definition
1. Foreign Covered Funds
2. Commodity Pools
3. Entities Regulated Under the Investment
Company Act
c. Entities Excluded From Definition of
Covered Fund
1. Foreign Public Funds
2. Wholly-Owned Subsidiaries
3. Joint Ventures
4. Acquisition Vehicles
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5. Foreign Pension or Retirement Funds
6. Insurance Company Separate Accounts
7. Bank Owned Life Insurance Separate
Accounts
8. Exclusion for Loan Securitizations and
Definition of Loan
a. Definition of Loan
b. Loan Securitizations
i. Loans
ii. Contractual Rights Or Assets
iii. Derivatives
iv. SUBIs and Collateral Certificates
v. Impermissible Assets
9. Asset-Backed Commercial Paper
Conduits
10. Covered Bonds
11. Certain Permissible Public Welfare and
Similar Funds
12. Registered Investment Companies and
Excluded Entities
13. Other Excluded Entities
d. Entities Not Specifically Excluded From
the Definition of Covered Fund
1. Financial Market Utilities
2. Cash Collateral Pools
3. Pass-Through REITS
4. Municipal Securities Tender Option
Bond Transactions
5. Venture Capital Funds
6. Credit Funds
7. Employee Securities Companies
e. Definition of ‘‘Ownership Interest’’
f. Definition of ‘‘Resident of the United
States’’
g. Definition of ‘‘Sponsor’’
2. Section ll.11: Activities Permitted in
Connection With Organizing and
Offering a Covered Fund
a. Scope of Exemption
1. Fiduciary Services
2. Compliance With Investment
Limitations
3. Compliance With Section 13(f) of the
BHC Act
4. No Guarantees or Insurance of Fund
Performance
5. Limitation on Name Sharing With a
Covered Fund
6. Limitation on Ownership By Directors
and Employees
7. Disclosure Requirements
b. Organizing and Offering an Issuing
Entity of Asset-Backed Securities
c. Underwriting and Market Making for a
Covered Fund
3. Section ll.12: Permitted Investment in
a Covered Fund
a. Proposed Rule
b. Duration of Seeding Period for New
Covered Funds
c. Limitations on Investments in a Single
Covered Fund (‘‘Per-Fund Limitation’’)
d. Limitation on Aggregate Permitted
Investments in All Covered funds
(‘‘Aggregate Funds Limitation’’)
e. Capital Treatment of an Investment in a
Covered Fund
f. Attribution of Ownership Interests to a
Banking Entity
g. Calculation of Tier 1 Capital
h. Extension of Time to Divest Ownership
Interest in a Single Fund
4. Section ll.13: Other Permitted
Covered Fund Activities
a. Permitted Risk-Mitigating Hedging
Activities
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b. Permitted Covered Fund Activities and
Investments Outside of the United States
1. Foreign Banking Entities Eligible for the
Exemption
2. Activities or Investments Solely Outside
of the United States
3. Offered for Sale or Sold to a Resident of
the United States
4. Definition of ‘‘Resident of the United
States’’
c. Permitted Covered Fund Interests and
Activities by a Regulated Insurance
Company
5. Section ll.14: Limitations on
Relationships With a Covered Fund
a. Scope of Application
b. Transactions That Would Be a ‘‘Covered
Transaction’’
c. Certain Transactions and Relationships
Permitted
1. Permitted Investments and Ownerships
Interests
2. Prime Brokerage Transactions
d. Restrictions on Transactions With Any
Permitted Covered Fund
6. Section ll.15: Other Limitations on
Permitted Covered Fund Activities
C. Subpart D and Appendices A and B—
Compliance Program, Reporting, and
Violations
1. Section ll.20: Compliance Program
Mandate
a. Program Requirement
b. Compliance Program Elements
c. Simplified Programs for Less Active
Banking Entities
d. Threshold for Application of Enhanced
Minimum Standards
2. Appendix B: Enhanced Minimum
Standards for Compliance Programs
a. Proprietary Trading Activities
b. Covered Fund Activities or Investments
c. Enterprise-Wide Programs
d. Responsibility and Accountability
e. Independent Testing
f. Training
g. Recordkeeping
3. Section ll.20(d) and Appendix A:
Reporting and Recordkeeping
Requirements Applicable to Trading
Activities
a. Approach to Reporting and
Recordkeeping Requirements Under the
Proposal
b. General Comments on the Proposed
Metrics
c. Approach of the Final Rule
d. Proposed Quantitative Measurements
and Comments on Specific Metrics
4. Section ll.21: Termination of
Activities or Investments; Authorities for
Violations
V. Administrative Law Matters
A. Use of Plain Language
B. Paperwork Reduction Act Analysis
C. Regulatory Flexibility Act Analysis
D. OCC Unfunded Mandates Reform Act of
1995 Determination
I. Background
The Dodd-Frank Act was enacted on
July 21, 2010.1 Section 619 of the Dodd1 Dodd-Frank Wall Street Reform and Consumer
Protection Act, Public Law 111–203, 124 Stat. 1376
(2010).
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Frank Act added a new section 13 to the
Bank Holding Company Act of 1956
(‘‘BHC Act’’) (codified at 12 U.S.C. 1851)
that generally prohibits any banking
entity from engaging in proprietary
trading or from acquiring or retaining an
ownership interest in, sponsoring, or
having certain relationships with a
hedge fund or private equity fund
(‘‘covered fund’’), subject to certain
exemptions.2 New section 13 of the BHC
Act also provides that a nonbank
financial company designated by the
Financial Stability Oversight Council
(‘‘FSOC’’) for supervision by the Board
(while not a banking entity under
section 13 of the BHC Act) would be
subject to additional capital
requirements, quantitative limits, or
other restrictions if the company
engages in certain proprietary trading or
covered fund activities.3
Section 13 of the BHC Act generally
prohibits banking entities from engaging
as principal in proprietary trading for
the purpose of selling financial
instruments in the near term or
otherwise with the intent to resell in
order to profit from short-term price
movements.4 Section 13(d)(1) expressly
exempts from this prohibition, subject
to conditions, certain activities,
including:
• Trading in U.S. government, agency
and municipal obligations;
• Underwriting and market makingrelated activities;
• Risk-mitigating hedging activities;
• Trading on behalf of customers;
• Trading for the general account of
insurance companies; and
• Foreign trading by non-U.S.
banking entities.5
Section 13 of the BHC Act also
generally prohibits banking entities
from acquiring or retaining an
ownership interest in, or sponsoring, a
hedge fund or private equity fund.
Section 13 contains several exemptions
that permit banking entities to make
limited investments in hedge funds and
private equity funds, subject to a
number of restrictions designed to
ensure that banking entities do not
rescue investors in these funds from loss
and are not themselves exposed to
2 See
12 U.S.C. 1851.
12 U.S.C. 1851(a)(2) and (f)(4). The Agencies
note that two of the three companies currently
designated by FSOC for supervision by the Board
are affiliated with insured depository institutions,
and are therefore currently banking entities for
purposes of section 13 of the BHC Act. The
Agencies are continuing to review whether the
remaining company engages in any activity subject
to section 13 of the BHC Act and what, if any,
requirements apply under section 13.
4 See 12 U.S.C. 1851(a)(1)(A) and (B).
5 See id. at 1851(d)(1).
3 See
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significant losses from investments or
other relationships with these funds.
Section 13 of the BHC Act does not
prohibit a nonbank financial company
supervised by the Board from engaging
in proprietary trading, or from having
the types of ownership interests in or
relationships with a covered fund that a
banking entity is prohibited or restricted
from having under section 13 of the
BHC Act. However, section 13 of the
BHC Act provides that these activities
be subject to additional capital charges,
quantitative limits, or other
restrictions.6
II. Notice of Proposed Rulemaking:
Summary of General Comments
Authority for developing and
adopting regulations to implement the
prohibitions and restrictions of section
13 of the BHC Act is divided among the
Board, the Federal Deposit Insurance
Corporation (‘‘FDIC’’), the Office of the
Comptroller of the Currency (‘‘OCC’’),
the Securities and Exchange
Commission (‘‘SEC’’), and the
Commodity Futures Trading
Commission (‘‘CFTC’’).7 As required by
section 13(b)(2) of the BHC Act, the
Board, OCC, FDIC, and SEC in October
2011 invited the public to comment on
proposed rules implementing that
section’s requirements.8 The period for
filing public comments on this proposal
was extended for an additional 30 days,
until February 13, 2012.9 In January
2012, the CFTC requested comment on
a proposal for the same common rule to
implement section 13 with respect to
those entities for which it is the primary
financial regulatory agency and invited
public comment on its proposed
implementing rule through April 16,
6 See
12 U.S.C. 1851(a)(2) and (d)(4).
12 U.S.C. 1851(b)(2). Under section
13(b)(2)(B) of the BHC Act, rules implementing
section 13’s prohibitions and restrictions must be
issued by: (i) The appropriate Federal banking
agencies (i.e., the Board, the OCC, and the FDIC),
jointly, with respect to insured depository
institutions; (ii) the Board, with respect to any
company that controls an insured depository
institution, or that is treated as a bank holding
company for purposes of section 8 of the
International Banking Act, any nonbank financial
company supervised by the Board, and any
subsidiary of any of the foregoing (other than a
subsidiary for which an appropriate Federal
banking agency, the SEC, or the CFTC is the
primary financial regulatory agency); (iii) the CFTC
with respect to any entity for which it is the
primary financial regulatory agency, as defined in
section 2 of the Dodd-Frank Act; and (iv) the SEC
with respect to any entity for which it is the
primary financial regulatory agency, as defined in
section 2 of the Dodd-Frank Act. See id.
8 See 76 FR 68846 (Nov. 7, 2011) (‘‘Joint
Proposal’’).
9 See 77 FR 23 (Jan. 23, 2012) (extending the
comment period to February 13, 2012).
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7 See
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2012.10 The statute requires the
Agencies, in developing and issuing
implementing rules, to consult and
coordinate with each other, as
appropriate, for the purposes of
assuring, to the extent possible, that
such rules are comparable and provide
for consistent application and
implementation of the applicable
provisions of section 13 of the BHC
Act.11
The proposed rules invited comment
on a multi-faceted regulatory framework
to implement section 13 consistent with
the statutory language. In addition, the
Agencies invited comments on the
potential economic impacts of the
proposed rule and posed a number of
questions seeking information on the
costs and benefits associated with each
aspect of the proposal, as well as on any
significant alternatives that would
minimize the burdens or amplify the
benefits of the proposal in a manner
consistent with the statute. The
Agencies also encouraged commenters
to provide quantitative information and
data about the impact of the proposal on
entities subject to section 13, as well as
on their clients, customers, and
counterparties, specific markets or asset
classes, and any other entities
potentially affected by the proposed
rule, including non-financial small and
mid-size businesses.
The Agencies received over 18,000
comments addressing a wide variety of
aspects of the proposal, including
definitions used by the proposal and the
exemptions for market making-related
activities, risk-mitigating hedging
activities, covered fund activities and
investments, the use of quantitative
metrics, and the reporting proposals.
The vast majority of these comments
were from individuals using a version of
a short form letter to express support for
the proposed rule. More than 600
comment letters were unique comment
letters, including from members of
Congress, domestic and foreign banking
entities and other financial services
firms, trade groups representing
banking, insurance, and the broader
financial services industry, U.S. state
and foreign governments, consumer and
public interest groups, and individuals.
To improve understanding of the issues
raised by commenters, the Agencies met
with a number of these commenters to
discuss issues relating to the proposed
rule, and summaries of these meetings
10 See 77 FR 8332 (Feb. 14, 2012) (‘‘CFTC
Proposal’’).
11 See 12 U.S.C. 1851(b)(2)(B)(ii). The Secretary of
the Treasury, as Chairperson of the FSOC, is
responsible for coordinating the Agencies’
rulemakings under section 13 of the BHC Act. See
id.
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are available on each of the Agency’s
public Web sites.12 The CFTC staff also
hosted a public roundtable on the
proposed rule.13 Many of the
commenters generally expressed
support for the broader goals of the
proposed rule. At the same time, many
commenters expressed concerns about
various aspects of the proposed rule.
Many of these commenters requested
that one or more aspects of the proposed
rule be modified in some manner in
order to reflect their viewpoints and to
better accommodate the scope of
activities that they argued were
encompassed within section 13 of the
BHC Act. The comments addressed all
major sections of the proposed rule.
Section 13 of the BHC Act also
required the FSOC to conduct a study
(‘‘FSOC study’’) and make
recommendations to the Agencies by
January 21, 2011 on the implementation
of section 13 of the BHC Act. The FSOC
study was issued on January 18, 2011.
The FSOC study included a detailed
discussion of key issues related to
implementation of section 13 and
recommended that the Agencies
consider taking a number of specified
actions in issuing rules under section 13
of the BHC Act.14 The FSOC study also
recommended that the Agencies adopt a
four-part implementation and
supervisory framework for identifying
and preventing prohibited proprietary
trading, which included a programmatic
compliance regime requirement for
banking entities, analysis and reporting
of quantitative metrics by banking
entities, supervisory review and
oversight by the Agencies, and
12 See https://www.regulations.gov/#!docketDetail;
D=OCC-2011-0014 (OCC); https://www.federal
reserve.gov/newsevents/reform_systemic.htm
(Board); https://www.fdic.gov/regulations/laws/
federal/2011/11comAD85.html (FDIC); https://
www.sec.gov/comments/s7-41-11/s74111.shtml
(SEC); and https://www.cftc.gov/LawRegulation/
DoddFrankAct/Rulemakings/DF_28_VolckerRule/
index.htm (CFTC).
13 See Commodity Futures Trading Commission,
CFTC Staff to Host a Public Roundtable to Discuss
the Proposed Volcker Rule (May 24, 2012),
available at https://www.cftc.gov/PressRoom/
PressReleases/pr6263-12; transcript available at
https://www.cftc.gov/ucm/groups/public/@
newsroom/documents/file/transcript053112.pdf.
14 See Financial Stability Oversight Counsel,
Study and Recommendations on Prohibitions on
Proprietary Trading and Certain Relationships with
Hedge Funds and Private Equity Funds (Jan. 18,
2011), available at https://www.treasury.gov/
initiatives/Documents/Volcker%20sec%20619%
20study%20final%201%2018%2011%20rg.pdf.
(‘‘FSOC study’’). See 12 U.S.C. 1851(b)(1). Prior to
publishing its study, FSOC requested public
comment on a number of issues to assist in
conducting its study. See 75 FR 61,758 (Oct. 6,
2010). Approximately 8,000 comments were
received from the public, including from members
of Congress, trade associations, individual banking
entities, consumer groups, and individuals.
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enforcement procedures for violations.15
The Agencies carefully considered the
FSOC study and its recommendations.
In formulating this final rule, the
Agencies carefully reviewed all
comments submitted in connection with
the rulemaking and considered the
suggestions and issues they raise in light
of the statutory restrictions and
provisions as well as the FSOC study.
The Agencies have sought to reasonably
respond to all of the significant issues
commenters raised. The Agencies
believe they have succeeded in doing so
notwithstanding the complexities
involved. The Agencies also carefully
considered different options suggested
by commenters in light of potential
costs and benefits in order to effectively
implement section 13 of the BHC Act.
The Agencies made numerous changes
to the final rule in response to the issues
and information provided by
commenters. These modifications to the
rule and explanations that address
comments are described in more detail
in the section-by-section description of
the final rule. To enhance uniformity in
both rules that implement section 13
and administration of the requirements
of that section, the Agencies have been
regularly consulting with each other in
the development of this final rule.
Some commenters requested that the
Agencies repropose the rule and/or
delay adoption pending the collection of
additional information.16 As described
in part above, the Agencies have
provided many and various types of
opportunities for commenters to provide
input on implementation of section 13
of the BHC Act and have collected
substantial information in the process.
In addition to the official comment
process described above, members of
the public submitted comment letters in
advance of the official comment period
for the proposed rules and met with
staff of the Agencies to explain issues of
concern; the public also provided
substantial comment in response to a
request for comment from the FSOC
regarding its findings and
recommendations for implementing
section 13.17 The Agencies provided a
detailed proposal and posed numerous
15 See
FSOC study at 5–6.
e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); ABA (Keating); Chamber (Nov. 2011);
Chamber (Nov. 2013); Members of Congress (Dec.
2011); IIAC; Real Estate Roundtable; Ass’n. of
German Banks; Allen & Overy (Clearing); JPMC;
Goldman (Prop. Trading); BNY Mellon et al.; State
Street (Feb. 2012); ICI Global; Chamber (Feb. 2012);
´ ´ ´ ´
Societe Generale; HSBC; Western Asset Mgmt.;
Abbott Labs et al. (Feb. 2012); PUC Texas; Columbia
Mgmt.; ICI (Feb. 2012); IIB/EBF; British Bankers’
Ass’n.; ISDA (Feb. 2012); Comm. on Capital Markets
Regulation; Ralph Saul (Apr. 2012); BPC.
17 See 75 FR 61,758 (Oct. 6, 2010).
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16 See,
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questions in the preamble to the
proposal to solicit and explore
alternative approaches in many areas. In
addition, the Agencies have continued
to receive comment letters after the
extended comment period deadline,
which the Agencies have considered.
Thus, the Agencies believe interested
parties have had ample opportunity to
review the proposed rules, as well as the
comments made by others, and to
provide views on the proposal, other
comment letters, and data to inform our
consideration of the final rules.
In addition, the Agencies have been
mindful of the importance of providing
certainty to banking entities and
financial markets and of providing
sufficient time for banking entities to
understand the requirements of the final
rule and to design, test, and implement
compliance and reporting systems. The
further substantial delay that would
necessarily be entailed by reproposing
the rule would extend the uncertainty
that banking entities would face, which
could prove disruptive to banking
entities and the financial markets.
The Agencies note, as discussed more
fully below, that the final rule
incorporates a number of modifications
designed to address the issues raised by
commenters in a manner consistent
with the statute. The preamble below
also discusses many of the issues raised
by commenters and explains the
Agencies’ response to those comments.
To achieve the purpose of the statute,
without imposing unnecessary costs, the
final rule builds on the multi-faceted
approach in the proposal, which
includes development and
implementation of a compliance
program at each banking entity engaged
in trading activities or that makes
investments subject to section 13 of the
BHC Act; the collection and evaluation
of data regarding these activities as an
indicator of areas meriting additional
attention by the banking entity and the
relevant agency; appropriate limits on
trading, hedging, investment and other
activities; and supervision by the
Agencies. To allow banking entities
sufficient time to develop appropriate
systems, the Agencies have provided for
a phased-in schedule for the collection
of data, limited data reporting
requirements only to banking entities
that engage in significant trading
activity, and agreed to review the merits
of the data collected and revise the data
collection as appropriate over the next
21 months. Importantly, as explained in
detail below, the Agencies have also
reduced the compliance burden for
banking entities with total assets of less
than $10 billion. The final rule also
eliminates compliance burden for firms
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that do not engage in covered activities
or investments beyond investing in U.S.
government obligations, agency
guaranteed obligations, or municipal
obligations.
Moreover, the Agencies believe the
data that will be collected in connection
with the final rule, as well as the
compliance efforts made by banking
entities and the supervisory experience
that will be gained by the Agencies in
reviewing trading and investment
activity under the final rule, will
provide valuable insights into the
effectiveness of the final rule in
achieving the purpose of section 13 of
the BHC Act. The Agencies remain
committed to implementing the final
rule, and revisiting and revising the rule
as appropriate, in a manner designed to
ensure that the final rule faithfully
implements the requirements and
purposes of the statute.18
Finally, the Board has determined, in
accordance with section 13 of the BHC
Act, to provide banking entities with
additional time to conform their
activities and investments to the statute
and the final rule. The restrictions and
prohibitions of section 13 of the BHC
Act became effective on July 21, 2012.19
The statute provided banking entities a
period of two years to conform their
activities and investments to the
requirement of the statute, until July 21,
2014. Section 13 also permits the Board
to extend this conformance period, one
year at a time, for a total of no more than
three additional years.20 Pursuant to this
authority and in connection with this
rulemaking, the Board has in a separate
action extended the conformance period
for an additional year until July 21,
2015.21 The Board will continue to
monitor developments to determine
whether additional extensions of the
conformance period are in the public
interest, consistent with the statute.
Accordingly, the Agencies do not
believe that a reproposal or further
delay is necessary or appropriate.
Commenters have differing views on
the overall economic impacts of section
13 of the BHC Act.
18 If any provision of this rule, or the application
thereof to any person or circumstance, is held to be
invalid, such invalidity shall not affect other
provisions or application of such provisions to
other persons or circumstances that can be given
effect without the invalid provision or application.
19 See 12 U.S.C. 1851(c)(1).
20 See 12 U.S.C. 1851(c)(2); See also, A
Conformance Period for Entities Engaged in
Prohibited Proprietary Trading or Private Equity
Fund or Hedge Fund Activities, 76 FR 8265 (Feb.
14, 2011) (citing 156 Cong. Rec. S5898 (daily ed.
July 15, 2010) (statement of Sen. Merkley)).
21 See, Board Order Approving Extension of
Conformance Period, available at https://
www.federalreserve.gov/newsevents/press/bcreg/
bcreg20131210b1.pdf.
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Some commenters remarked that
proprietary trading restrictions will
have detrimental impacts on the
economy such as: reduction in
efficiency of markets, economic growth,
and in employment due to a loss in
liquidity.22 In particular, a commenter
expressed concern that there may be
high transition costs as non-banking
entities replace some of the trading
activities currently performed by
banking entities.23 Another commenter
focused on commodity markets
remarked about the potential reduction
in commercial output and curtailed
resource exploration due to a lack of
hedging counterparties.24 Several
commenters stated that section 13 of the
BHC Act will reduce access to debt
markets—especially for smaller
companies—raising the costs of capital
for firms and lowering the returns on
certain investments.25 Further, some
commenters mentioned that U.S. banks
may be competitively disadvantaged
relative to foreign banks due to
proprietary trading restrictions and
compliance costs.26
On the other hand, other commenters
stated that restricting proprietary
trading activity by banking entities may
reduce systemic risk emanating from the
financial system and help to lower the
probability of the occurrence of another
financial crisis.27 One commenter
contended that large banking entities
may have a moral hazard incentive to
engage in risky activities without
allocating sufficient capital to them,
especially if market participants believe
these institutions will not be allowed to
fail.28 Commenters argued that large
banking entities may engage in activities
that increase the upside return at the
expense of downside loss exposure
which may ultimately be borne by
Federal taxpayers 29 and that subsidies
associated with bank funding may
create distorted economic outcomes.30
Furthermore, some commenters
remarked that non-banking entities may
fill much of the void in liquidity
22 See, e.g., Oliver Wyman (Dec. 2011); Chamber
(Dec. 2011); Thakor Study; Prof. Duffie; IHS.
23 See Prof. Duffie.
24 See IHS.
25 See, e.g., Chamber (Dec. 2011); Thakor Study;
Oliver Wyman (Dec. 2011); IHS.
26 See, e.g., RBC; Citigroup (Feb. 2012); Goldman
(Covered Funds).
27 See, e.g., Profs. Admati & Pfleiderer; AFR (Nov.
2012); Better Markets (Dec. 2011); Better Markets
(Feb. 2012); Occupy; Johnson & Prof. Stiglitz; Paul
Volcker.
28 See Occupy.
29 See Profs. Admati & Pfleiderer; Better Markets
(Feb. 2012); Occupy; Johnson & Prof. Stiglitz; Paul
Volcker.
30 See Profs. Admati & Pfleiderer; Johnson & Prof.
Stiglitz.
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provision left by banking entities if
banking entities reduce their current
trading activities.31 Finally, some
commenters mentioned that hyperliquidity that arises from, for instance,
speculative bubbles, may harm the
efficiency and price discovery function
of markets.32
The Agencies have taken these
concerns into account in the final rule.
As described below with respect to
particular aspects of the final rule, the
Agencies have addressed these issues by
reducing burdens where appropriate,
while at the same time ensuring that the
final rule serves its purpose of
promoting healthy economic activity. In
that regard, the Agencies have sought to
achieve the balance intended by
Congress under section 13 of the BHC
Act. Several comments suggested that a
costs and benefits analysis be performed
by the Agencies.33 On the other hand,
some commenters 34 correctly stated
that a costs and benefits analysis is not
legally required.35 However, the
Agencies find certain of the information
submitted by commenters concerning
costs and benefits and economic effects
to be relevant to consideration of the
rule, and so have considered this
information as appropriate, and, on the
basis of these and other considerations,
sought to achieve the balance intended
by Congress in section 619 of the DoddFrank Act. The relevant comments are
addressed therein.
III. Overview of Final Rule
The Agencies are adopting this final
rule to implement section 13 of the BHC
Act with a number of changes to the
proposal, as described further below.
The final rule adopts a risk-based
approach to implementation that relies
on a set of clearly articulated
characteristics of both prohibited and
permitted activities and investments
and is designed to effectively
accomplish the statutory purpose of
reducing risks posed to banking entities
by proprietary trading activities and
investments in or relationships with
covered funds. As explained more fully
31 See AFR et al. (Feb. 2012); Better Markets (Apr.
16, 2012); David McClean; Public Citizen; Occupy.
32 See Johnson & Prof. Stiglitz (citing Thomas
Phillipon (2011)); AFR et al. (Feb. 2012); Occupy.
33 See SIFMA et al. (Covered Funds) (Feb. 2012);
´ ´
BoA; ABA (Keating); Chamber (Feb. 2012); Societe
´ ´
Generale; FTN; SVB; ISDA (Feb. 2012); Comm. on
Capital Market Regulation; Real Estate Roundtable.
34 See, e.g., Better Markets (Feb. 2012); Randel
Pilo.
35 For example, with respect to the CFTC, Section
15(a) of the CEA requires such consideration only
when ‘‘promulgating a regulation under this
[Commodity Exchange] Act.’’ This final rule is not
promulgated under the CEA, but under the BHC
Act. CEA section 15(a), therefore, does not apply.
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5541
below in the section-by-section analysis,
the final rule has been designed to
ensure that banking entities do not
engage in prohibited activities or
investments and to ensure that banking
entities engage in permitted trading and
investment activities in a manner
designed to identify, monitor and limit
the risks posed by these activities and
investments. For instance, the final rule
requires that any banking entity that is
engaged in activity subject to section 13
develop and administer a compliance
program that is appropriate to the size,
scope and risk of its activities and
investments. The rule requires the
largest firms engaged in these activities
to develop and implement enhanced
compliance programs and regularly
report data on trading activities to the
Agencies. The Agencies believe this will
permit banking entities to effectively
engage in permitted activities, and the
Agencies to enforce compliance with
section 13 of the BHC Act. In addition,
the enhanced compliance programs will
help both the banking entities and the
Agencies identify, monitor, and limit
risks of activities permitted under
section 13, particularly involving
banking entities posing the greatest risk
to financial stability.
A. General Approach and Summary of
Final Rule
The Agencies have designed the final
rule to achieve the purposes of section
13 of the BHC Act, which include
prohibiting banking entities from
engaging in proprietary trading or
acquiring or retaining an ownership
interest in, or having certain
relationships with, a covered fund,
while permitting banking entities to
continue to provide, and to manage and
limit the risks associated with
providing, client-oriented financial
services that are critical to capital
generation for businesses of all sizes,
households and individuals, and that
facilitate liquid markets. These clientoriented financial services, which
include underwriting, market making,
and asset management services, are
important to the U.S. financial markets
and the participants in those markets.
At the same time, providing appropriate
latitude to banking entities to provide
such client-oriented services need not
and should not conflict with clear,
robust, and effective implementation of
the statute’s prohibitions and
restrictions.
As noted above, the final rule takes a
multi-faceted approach to implementing
section 13 of the BHC Act. In particular,
the final rule includes a framework that
clearly describes the key characteristics
of both prohibited and permitted
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activities. The final rule also requires
banking entities to establish a
comprehensive compliance program
designed to ensure compliance with the
requirements of the statute and rule in
a way that takes into account and
reflects the banking entity’s activities,
size, scope and complexity. With
respect to proprietary trading, the final
rule also requires the large firms that are
active participants in trading activities
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.
As a matter of structure, the final rule
is generally divided into four subparts
and contains two appendices, as
follows:
• Subpart A of the final rule describes
the authority, scope, purpose, and
relationship to other authorities of the
rule and defines terms used commonly
throughout the rule;
• Subpart B of the final rule prohibits
proprietary trading, defines terms
relevant to covered trading activity,
establishes exemptions from the
prohibition on proprietary trading and
limitations on those exemptions, and
requires certain banking entities to
report quantitative measurements with
respect to their trading activities;
• Subpart C of the final rule prohibits
or restricts acquiring or retaining an
ownership interest in, and certain
relationships with, a covered fund,
defines terms relevant to covered fund
activities and investments, as well as
establishes exemptions from the
restrictions on covered fund activities
and investments and limitations on
those exemptions;
• Subpart D of the final rule generally
requires banking entities to establish a
compliance program regarding
compliance with section 13 of the BHC
Act and the final rule, including written
policies and procedures, internal
controls, a management framework,
independent testing of the compliance
program, training, and recordkeeping;
• Appendix A of the final rule details
the quantitative measurements that
certain banking entities may be required
to compute and report with respect to
certain trading activities;
• Appendix B of the final rule details
the enhanced minimum standards for
programmatic compliance that certain
banking entities must meet with respect
to their compliance program, as
required under subpart D.
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B. Proprietary Trading Restrictions
Subpart B of the final rule implements
the statutory prohibition on proprietary
trading and the various exemptions to
this prohibition included in the statute.
Section ll.3 of the final rule contains
the core prohibition on proprietary
trading and defines a number of related
terms, including ‘‘proprietary trading’’
and ‘‘trading account.’’ The final rule’s
definition of proprietary trading
generally parallels the statutory
definition and covers engaging as
principal for the trading account of a
banking entity in any transaction to
purchase or sell specified types of
financial instruments.36
The final rule’s definition of trading
account also is consistent with the
statutory definition.37 In particular, the
definition of trading account in the final
rule includes three classes of positions.
First, the definition includes the
purchase or sale of one or more
financial instruments taken principally
for the purpose of short-term resale,
benefitting from short-term price
movements, realizing short-term
arbitrage profits, or hedging another
trading account position.38 For purposes
of this part of the definition, the final
rule also contains a rebuttable
presumption that the purchase or sale of
a financial instrument by a banking
entity is for the trading account of the
banking entity if the banking entity
holds the financial instrument for fewer
than 60 days or substantially transfers
the risk of the financial instrument
within 60 days of purchase (or sale).39
Second, with respect to a banking entity
subject to the Federal banking agencies’
Market Risk Capital Rules, the
definition includes the purchase or sale
of one or more financial instruments
subject to the prohibition on proprietary
trading that are treated as ‘‘covered
positions and trading positions’’ (or
hedges of other market risk capital rule
covered positions) under those capital
rules, other than certain foreign
exchange and commodities positions.40
Third, the definition includes the
purchase or sale of one or more
financial instruments by a banking
entity that is licensed or registered or
required to be licensed or registered to
engage in the business of a dealer, swap
dealer, or security-based swap dealer to
the extent the instrument is purchased
or sold in connection with the activities
that require the banking entity to be
licensed or registered as such or is
final rule § ll.3(a).
final rule § ll.3(b).
38 See final rule § ll.3(b)(1)(i).
39 See final rule § ll.3(b)(2).
40 See final rule § ll.3(b)(1)(ii).
36 See
engaged in those businesses outside of
the United States, to the extent the
instrument is purchased or sold in
connection with the activities of such
business.41
The definition of proprietary trading
also contains clarifying exclusions for
certain purchases and sales of financial
instruments that generally do not
involve the requisite short-term trading
intent, such as the purchase and sale of
financial instruments arising under
certain repurchase and reverse
repurchase arrangements or securities
lending transactions and securities
acquired or taken for bona fide liquidity
management purposes.42
In Section ll.3, the final rule also
defines a number of other relevant
terms, including the term ‘‘financial
instrument.’’ This term is used to define
the scope of financial instruments
subject to the prohibition on proprietary
trading. Consistent with the statutory
language, such financial instruments
include securities, derivatives,
commodity futures, and options on such
instruments, but do not include loans,
spot foreign exchange or spot physical
commodities.43
In Section ll.4, the final rule
implements the statutory exemptions for
underwriting and market making-related
activities. For each of these permitted
activities, the final rule defines the
exempt activity and provides a number
of requirements that must be met in
order for a banking entity to rely on the
applicable exemption. As more fully
discussed below, these include
establishment and enforcement of a
compliance program targeted to the
activity; limits on positions, inventory
and risk exposure addressing the
requirement that activities be designed
not to exceed the reasonably expected
near term demands of clients,
customers, or counterparties; limits on
the duration of holdings and positions;
defined escalation procedures to change
or exceed limits; analysis justifying
established limits; internal controls and
independent testing of compliance with
limits; senior management
accountability and limits on incentive
compensation. In addition, the final rule
requires firms with significant marketmaking or underwriting activities to
report data involving several metrics
that may be used by the banking entity
and the Agencies to identify trading
activity that may warrant more detailed
compliance review.
These requirements are generally
designed to ensure that the banking
37 See
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final rule § ll.3(b)(1)(iii).
final rule § ll.3(d).
43 See final rule § ll.3(c).
41 See
42 See
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entity’s trading activity is limited to
underwriting and market making-related
activities and does not include
prohibited proprietary trading.44 These
requirements are also intended to work
together to ensure that banking entities
identify, monitor and limit the risks
associated with these activities.
In Section ll.5, the final rule
implements the statutory exemption for
risk-mitigating hedging. As with the
underwriting and market-making
exemptions, § ll.5 of the final rule
contains a number of requirements that
must be met in order for a banking
entity to rely on the exemption. These
requirements are generally designed to
ensure that the banking entity’s hedging
activity is limited to risk-mitigating
hedging in purpose and effect.45 Section
ll.5 also requires banking entities to
document, at the time the transaction is
executed, the hedging rationale for
certain transactions that present
heightened compliance risks.46 As with
the exemptions for underwriting and
market making-related activity, these
requirements form part of a broader
implementation approach that also
includes the compliance program
requirement and the reporting of
quantitative measurements.
In Section ll.6, the final rule
implements statutory exemptions for
trading in certain government
obligations, trading on behalf of
customers, trading by a regulated
insurance company, and trading by
certain foreign banking entities outside
of the United States. Section ll.6(a) of
the final rule describes the government
obligations in which a banking entity
may trade, which include U.S.
government and agency obligations,
obligations and other instruments of
specified government sponsored
entities, and State and municipal
obligations.47 Section ll.6(b) of the
final rule permits trading in certain
foreign government obligations by
affiliates of foreign banking entities in
the United State and foreign affiliates of
a U.S. banking entity abroad.48 Section
ll.6(c) of the final rule describes
permitted trading on behalf of
customers and identifies the types of
transactions that would qualify for the
exemption.49 Section ll.6(d) of the
final rule describes permitted trading by
a regulated insurance company or an
affiliate thereof for the general account
of the insurance company, and also
final rule § ll.4(a), (b).
final rule § ll.5.
46 See final rule § ll.5(c).
47 See final rule § ll.6(a).
48 See final rule § ll.6(b).
49 See final rule § ll.6(c).
44 See
permits those entities to trade for a
separate account of the insurance
company.50 Finally, § ll.6(e) of the
final rule describes trading permitted
outside of the United States by a foreign
banking entity.51 The exemption in the
final rule clarifies when a foreign
banking entity will qualify to engage in
such trading pursuant to sections 4(c)(9)
or 4(c)(13) of the BHC Act, as required
by the statute, including with respect to
a foreign banking entity not currently
subject to the BHC Act. As explained in
detail below, the exemption also
provides that the risk as principal, the
decision-making, and the accounting for
this activity must occur solely outside of
the United States, consistent with the
statute.
In Section ll.7, the final rule
prohibits a banking entity from relying
on any exemption to the prohibition on
proprietary trading if the permitted
activity would involve or result in a
material conflict of interest, result in a
material exposure to high-risk assets or
high-risk trading strategies, or pose a
threat to the safety and soundness of the
banking entity or to the financial
stability of the United States.52 This
section also describes the terms material
conflict of interest, high-risk asset, and
high-risk trading strategy for these
purposes.
C. Restrictions on Covered Fund
Activities and Investments
Subpart C of the final rule implements
the statutory prohibition on, directly or
indirectly, acquiring and retaining an
ownership interest in, or having certain
relationships with, a covered fund, as
well as the various exemptions to this
prohibition included in the statute.
Section ll.10 of the final rule contains
the core prohibition on covered fund
activities and investments and defines a
number of related terms, including
‘‘covered fund’’ and ‘‘ownership
interest.’’ 53 The definition of covered
fund contains a number of exclusions
for entities that may rely on exclusions
from the Investment Company Act of
1940 contained in section 3(c)(1) or
3(c)(7) of that Act but that are not
engaged in investment activities of the
type contemplated by section 13 of the
BHC Act. These include, for example,
exclusions for wholly owned
subsidiaries, joint ventures, foreign
pension or retirement funds, insurance
company separate accounts, and public
welfare investment funds. The final rule
also implements the statutory rule of
45 See
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final rule § ll.6(d).
final rule § ll.6(e).
52 See final rule § ll.7.
53 See final rule § ll.10(b).
50 See
51 See
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5543
construction in section 13(g)(2) and
provides that a securitization of loans,
which would include loan
securitization, qualifying asset backed
commercial paper conduit, and
qualifying covered bonds, is not covered
by section 13 or the final rule.54
The definition of ‘‘ownership
interest’’ in the final rule provides
further guidance regarding the types of
interests that would be considered to be
an ownership interest in a covered
fund.55 As described in this
Supplementary Information, these
interests may take various forms. The
definition of ownership interest also
explicitly excludes from the definition
‘‘restricted profit interest’’ that is solely
performance compensation for services
provided to the covered fund by the
banking entity (or an employee or
former employee thereof), under certain
circumstances.56 Section ll.10 of the
final rule also defines a number of other
relevant terms, including the terms
‘‘prime brokerage transaction,’’
‘‘sponsor,’’ and ‘‘trustee.’’
Section ll.11 of the final rule
implements the exemption for
organizing and offering a covered fund
provided for under section 13(d)(1)(G)
of the BHC Act. Section ll.11(a) of the
final rule outlines the conditions that
must be met in order for a banking
entity to organize and offer a covered
fund under this authority. These
requirements are contained in the
statute and are intended to allow a
banking entity to engage in certain
traditional asset management and
advisory businesses, subject to certain
limits contained in section 13 of the
BHC Act.57 The requirements are
discussed in detail in Part IV.B.2. of this
SUPPLEMENTARY INFORMATION. Section
ll.11 also explains how these
requirements apply to covered funds
that are issuing entities of asset-backed
securities, as well as implements the
statutory exemption for underwriting
and market-making ownership interests
of a covered fund, including explaining
the limitations imposed on such
activities under the final rule.
In Section ll.12, the final rule
permits a banking entity to acquire and
54 The Agencies believe that most securitization
transactions are currently structured so that the
issuing entity with respect to the securitization is
not an affiliate of a banking entity under the BHC
Act. However, with respect to any securitization
that is an affiliate of a banking entity and that does
not meet the requirements of the loan securitization
exclusion, the related banking entity will need to
determine how to bring the securitization into
compliance with this rule.
55 See final rule § ll.10(d)(6).
56 See final rule § ll.10(b)(6)(ii).
57 See 156 Cong. Rec. S5889 (daily ed. July 15,
2010) (statement of Sen. Hagan).
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retain, as an investment in a covered
fund, an ownership interest in a covered
fund that the banking entity organizes
and offers or holds pursuant to other
authority under § ll.11.58 This section
implements section 13(d)(4) of the BHC
Act and related provisions. Section
13(d)(4)(A) of the BHC Act permits a
banking entity to make an investment in
a covered fund that the banking entity
organizes and offers, or for which it acts
as sponsor, for the purposes of (i)
establishing the covered fund and
providing the fund with sufficient
initial equity for investment to permit
the fund to attract unaffiliated investors,
or (ii) making a de minimis investment
in the covered fund in compliance with
applicable requirements. Section ll
.12 of the final rule implements this
authority and related limitations,
including limitations regarding the
amount and value of any individual perfund investment and the aggregate value
of all such permitted investments. In
addition, § ll.12 requires that the
aggregate value of all investments in
covered funds, plus any earnings on
these investments, be deducted from the
capital of the banking entity for
purposes of the regulatory capital
requirements, and explains how that
deduction must occur. Section ll.12
of the final rule also clarifies how a
banking entity must calculate its
compliance with these investment
limitations (including by deducting
such investments from applicable
capital, as relevant), and sets forth how
a banking entity may request an
extension of the period of time within
which it must conform an investment in
a single covered fund. This section also
explains how a banking entity must
apply the covered fund investment
limits to a covered fund that is an
issuing entity of asset backed securities
or a covered fund that is part of a
master-feeder or fund-of-funds
structure.
In Section ll.13, the final rule
implements the statutory exemptions
described in sections 13(d)(1)(C), (D),
(F), and (I) of the BHC Act that permit
a banking entity: (i) to acquire and
retain an ownership interest in a
covered fund as a risk-mitigating
hedging activity related to employee
compensation; (ii) in the case of a nonU.S. banking entity, to acquire and
retain an ownership interest in, or act as
sponsor to, a covered fund solely
outside the United States; and (iii) to
acquire and retain an ownership interest
in, or act as sponsor to, a covered fund
58 See
final rule § ll.12.
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by an insurance company for its general
or separate accounts.59
In Section ll.14, the final rule
implements section 13(f) of the BHC Act
and generally prohibits a banking entity
from entering into certain transactions
with a covered fund that would be a
covered transaction as defined in
section 23A of the Federal Reserve
Act.60 Section ll.14(a)(2) of the final
rule describes the transactions between
a banking entity and a covered fund that
remain permissible under the statute
and the final rule. Section ll.14(b) of
the final rule implements the statute’s
requirement that any transaction
permitted under section 13(f) of the
BHC Act (including a prime brokerage
transaction) between the banking entity
and a covered fund is subject to section
23B of the Federal Reserve Act,61 which,
in general, requires that the transaction
be on market terms or on terms at least
as favorable to the banking entity as a
comparable transaction by the banking
entity with an unaffiliated third party.
In Section ll.15, the final rule
prohibits a banking entity from relying
on any exemption to the prohibition on
acquiring and retaining an ownership
interest in, acting as sponsor to, or
having certain relationships with, a
covered fund, if the permitted activity
or investment would involve or result in
a material conflict of interest, result in
a material exposure to high-risk assets
or high-risk trading strategies, or pose a
threat to the safety and soundness of the
banking entity or to the financial
stability of the United States.62 This
section also describes material conflict
of interest, high-risk asset, and high-risk
trading strategy for these purposes.
D. Metrics Reporting Requirement
Under the final rule, a banking entity
that meets relevant thresholds specified
in the rule must furnish the following
quantitative measurements for each of
its trading desks engaged in covered
trading activity calculated in accordance
with Appendix A:
• Risk and Position Limits and Usage;
• Risk Factor Sensitivities;
• Value-at-Risk and Stress VaR;
• Comprehensive Profit and Loss
Attribution;
• Inventory Turnover;
• Inventory Aging; and
• Customer Facing Trade Ratio.
The final rule raises the threshold for
metrics reporting from the proposal to
capture only firms that engage in
final rule § ll.13(a)–(c).
60 See 12 U.S.C. 371c; see also final rule
§ ll.14.
61 12 U.S.C. 371c–1.
62 See final rule § ll.15.
59 See
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significant trading activity, identified at
specified aggregate trading asset and
liability thresholds, and delays the dates
for reporting metrics through a phasedin approach based on the size of trading
assets and liabilities. Specifically, the
Agencies have delayed the reporting of
metrics until June 30, 2014 for the
largest banking entities that, together
with their affiliates and subsidiaries,
have trading assets and liabilities the
average gross sum of which equal or
exceed $50 billion on a worldwide
consolidated basis over the previous
four calendar quarters (excluding
trading assets and liabilities involving
obligations of or guaranteed by the
United States or any agency of the
United States). Banking entities with
$25 billion or more in trading assets and
liabilities and banking entities with $10
billion or more in trading assets and
liabilities would also be required to
report these metrics beginning on April
30, 2016, and December 31, 2016,
respectively.
Under the final rule, a banking entity
required to report metrics must
calculate any applicable quantitative
measurement for each trading day. Each
banking entity required to report must
report each applicable quantitative
measurement to its primary supervisory
Agency on the reporting schedule
established in the final rule unless
otherwise requested by the primary
supervisory Agency for the entity. The
largest banking entities with $50 billion
in consolidated trading assets and
liabilities must report the metrics on a
monthly basis. Other banking entities
required to report metrics must do so on
a quarterly basis. All quantitative
measurements for any calendar month
must be reported no later than 10 days
after the end of the calendar month
required by the final rule unless another
time is requested by the primary
supervisory Agency for the entity except
for a transitional six month period
during which reporting will be required
no later than 30 days after the end of the
calendar month. Banking entities
subject to quarterly reporting will be
required to report quantitative
measurements within 30 days of the end
of the quarter, unless another time is
requested by the primary supervisory
Agency for the entity in writing.63
63 See final rule § ll.20(d)(3). The final rule
includes a shorter period of time for reporting
quantitative measurements than was proposed for
the largest banking entities. Like the monthly
reporting requirement for these firms, this is
intended to allow for more effective supervision of
their large-scale trading operations.
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E. Compliance Program Requirement
Subpart D of the final rule requires a
banking entity engaged in covered
trading activities or covered fund
activities to develop and implement a
program reasonably designed to ensure
and monitor compliance with the
prohibitions and restrictions on covered
trading activities and covered fund
activities and investments set forth in
section 13 of the BHC Act and the final
rule.64 To reduce the overall burden of
the rule, the final rule provides that a
banking entity that does not engage in
covered trading activities (other than
trading in U.S. government or agency
obligations, obligations of specified
government sponsored entities, and
state and municipal obligations) or
covered fund activities and investments
need only establish a compliance
program prior to becoming engaged in
such activities or making such
investments.65 In addition, to reduce the
burden on smaller banking entities, a
banking entity with total consolidated
assets of $10 billion or less that engages
in covered trading activities and/or
covered fund activities or investments
may satisfy the requirements of the final
rule by including in its existing
compliance policies and procedures
appropriate references to the
requirements of section 13 and the final
rule and adjustments as appropriate
given the activities, size, scope and
complexity of the banking entity.66
For banking entities with total assets
greater than $10 billion and less than
$50 billion, the final rule specifies six
elements that each compliance program
established under subpart D must, at a
minimum, include. These requirements
focus on written policies and
procedures reasonably designed to
ensure compliance with the final rules,
including limits on underwriting and
market-making; a system of internal
controls; clear accountability for
compliance and review of limits,
hedging, incentive compensation, and
other matters; independent testing and
audits; additional documentation for
covered funds; training; and
recordkeeping requirements.
A banking entity with $50 billion or
more total consolidated assets (or a
foreign banking entity that has total U.S.
assets of $50 billion or more) or that is
required to report metrics under
Appendix A is required to adopt an
enhanced compliance program with
more detailed policies, limits,
governance processes, independent
testing and reporting. In addition, the
final rule § ll.20.
final rule § ll.20(f)(1).
66 See final rule § ll.20(f)(2).
64 See
65 See
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Chief Executive Officer of these larger
banking entities must attest that the
banking entity has in place a program
reasonably designed to achieve
compliance with the requirements of
section 13 of the BHC Act and the final
rule.
The application of detailed minimum
standards for these types of banking
entities is intended to reflect the
heightened compliance risks of large
covered trading activities and covered
fund activities and investments and to
provide clear, specific guidance to such
banking entities regarding the
compliance measures that would be
required for purposes of the final rule.
IV. Final Rule
A. Subpart B—Proprietary Trading
Restrictions
1. Section ll.3: Prohibition on
Proprietary Trading and Related
Definitions
Section 13(a)(1)(A) of the BHC Act
prohibits a banking entity from engaging
in proprietary trading unless otherwise
permitted in section 13.67 Section
13(h)(4) of the BHC Act defines
proprietary trading, in relevant part, as
engaging as principal for the trading
account of the banking entity in any
transaction to purchase or sell, or
otherwise acquire or dispose of, a
security, derivative, contract of sale of a
commodity for future delivery, or other
financial instrument that the Agencies
include by rule.68
Section ll.3(a) of the proposed rule
implemented section 13(a)(1)(A) of the
BHC Act by prohibiting a banking entity
from engaging in proprietary trading
unless otherwise permitted under
§§ ll.4 through ll.6 of the proposed
rule. Section ll.3(b)(1) of the
proposed rule defined proprietary
trading in accordance with section
13(h)(4) of the BHC Act and clarified
that proprietary trading does not
include acting solely as agent, broker, or
custodian for an unaffiliated third party.
The preamble to the proposed rule
explained that acting in these types of
capacities does not involve trading as
principal.69
Several commenters expressed
concern about the breadth of the ban on
proprietary trading.70 Some of these
commenters stated that proprietary
trading must be carefully and narrowly
defined to avoid prohibiting activities
67 12
U.S.C. 1851(a)(1)(A).
U.S.C. 1851(h)(4).
69 See Joint Proposal, 76 FR 68,857.
70 See, e.g., Ass’n. of Institutional Investors (Feb.
2012); Capital Group; Comm. on Capital Markets
Regulation; IAA; SIFMA et al. (Prop. Trading) (Feb.
2012); SVB; Chamber (Feb. 2012); Wellington.
68 12
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5545
that Congress did not intend to limit
and to preclude significant, unintended
consequences for capital markets,
capital formation, and the broader
economy.71 Some commenters asserted
that the proposed definition could result
in banking entities being unwilling to
take principal risk to provide liquidity
for institutional investors; could
unnecessarily constrain liquidity in
secondary markets, forcing asset
managers to service client needs
through alternative non-U.S. markets;
could impose substantial costs for all
institutions, especially smaller and midsize institutions; and could drive risktaking to the shadow banking system.72
Others urged the Agencies to determine
that trading as agent, broker, or
custodian for an affiliate was not
proprietary trading.73
Commenters also suggested
alternative approaches for defining
proprietary trading. In general, these
approaches sought to provide a brightline definition to provide increased
certainty to banking entities74 or make
the prohibition easier to apply in
practice.75 One commenter stated the
Agencies should focus on the economics
of banking entities’ transactions and ban
trading if the banking entity is exposed
to market risk for a significant period of
time or is profiting from changes in the
value of the asset.76 Several
commenters, including individual
members of the public, urged the
Agencies to prohibit banking entities
from engaging in any kind of proprietary
trading and require separation of trading
from traditional banking activities.77
After carefully considering comments,
the Agencies are defining proprietary
trading as engaging as principal for the
trading account of the banking entity in
any purchase or sale of one or more
71 See Ass’n. of Institutional Investors (Feb. 2012);
GE (Feb. 2012); Invesco; Sen. Corker; Chamber (Feb.
2012).
72 See Chamber (Feb. 2012).
73 See Japanese Bankers Ass’n.
74 See, e.g., ABA (Keating); Ass’n. of Institutional
Investors (Feb. 2012); BOK; George Bollenbacher;
Credit Suisse (Seidel); NAIB et al.; SSgA (Feb.
2012); JPMC.
75 See Public Citizen.
76 See Sens. Merkley & Levin (Feb. 2012).
77 See generally Occupy; Public Citizen; AFR et
al. (Feb. 2012). The Agencies received over fifteen
thousand form letters in support of a rule with few
exemptions, many of which expressed a desire to
return to the regulatory scheme as governed by the
Glass-Steagall affiliation provisions of the U.S.
Banking Act of 1933, as repealed through the
Graham-Leach-Bliley Act of 1999. See generally
Sarah McGee; Christopher Wilson; Michael Itlis;
Barry Rein; Edward Bright. Congress rejected such
an approach, however, opting instead for the more
narrowly tailored regulatory approach embodied in
section 13 of the BHC Act.
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financial instruments.78 The Agencies
believe this effectively restates the
statutory definition. The Agencies are
not adopting commenters’ suggested
modifications to the proposed definition
of proprietary trading or the general
prohibition on proprietary trading
because they generally appear to be
inconsistent with Congressional intent.
For instance, some commenters
appeared to suggest an approach to
defining proprietary trading that would
capture only bright-line, speculative
proprietary trading and treat the
activities covered by the statutory
exemptions as completely outside the
rule.79 However, such an approach
would appear to be inconsistent with
Congressional intent because, for
instance, it would not give effect to the
limitations on permitted activities in
section 13(d) of the BHC Act.80 For
similar reasons, the Agencies are not
adopting a bright-line definition of
proprietary trading.81
A number of commenters expressed
concern that, as a whole, the proposed
rule may result in certain negative
economic impacts, including: (i)
Reduced market liquidity; 82 (ii) wider
spreads or otherwise increased trading
costs; 83 (iii) higher borrowing costs for
78 See final rule § ll.3(a). The final rule also
replaces all references to the proposed term
‘‘covered financial position’’ with the term
‘‘financial instrument.’’ This change has no
substantive impact because the definition of
‘‘financial instrument’’ is substantially identical to
the proposed definition of ‘‘covered financial
position.’’ Consistent with this change, the final
rule replaces the undefined verbs ‘‘acquire’’ or
‘‘take’’ with the defined terms ‘‘purchase’’ or ‘‘sale’’
and ‘‘sell.’’ See final rule §§ ll.3(c), ll.2(u), (x).
79 See, e.g., Ass’n. of Institutional Investors (Feb.
2012); GE (Feb. 2012); Invesco; Sen. Corker;
Chamber (Feb. 2012); JPMC.
80 See 156 Cong. Rec. S5895–96 (daily ed. July 15,
2010) (statement of Sen. Merkley) (stating the
statute ‘‘permits underwriting and market-makingrelated transactions that are technically trading for
the account of the firm but, in fact, facilitate the
provision of near-term client-oriented financial
services.’’).
81 See ABA (Keating); Ass’n. of Institutional
Investors (Feb. 2012); BOK; George Bollenbacher;
Credit Suisse (Seidel); NAIB et al.; SSgA (Feb.
2012); JPMC.
82 See, e.g., AllianceBernstein; Obaid Syed; Rep.
Bachus et al.; EMTA; NASP; Sen. Hagan; Investure;
Lord Abbett; Sumitomo Trust; EFAMA; Morgan
Stanley; Barclays; BoA; Citigroup (Feb. 2012);
STANY; ABA (Keating); ICE; ICSA; SIFMA (Asset
Mgmt.) (Feb. 2012); Putnam; ACLI (Feb. 2012);
Wells Fargo (Prop. Trading); Capital Group; RBC;
Columbia Mgmt.; SSgA (Feb. 2012); Fidelity; ICI
(Feb. 2012); ISDA (Feb. 2012); Comm. on Capital
Markets Regulation; Clearing House Ass’n.; Thakor
Study. See also CalPERS (acknowledging that the
systemic protections afforded by the Volcker Rule
come at a price, including reduced liquidity to all
markets).
83 See, e.g., AllianceBernstein; Obaid Syed;
NASP; Investure; Lord Abbett; CalPERS; Credit
Suisse (Seidel); Citigroup (Feb. 2012); ABA
(Keating); SIFMA (Asset Mgmt.) (Feb. 2012);
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businesses or increased cost of
capital; 84 and/or (iv) greater market
volatility.85 The Agencies have carefully
considered commenters’ concerns about
the proposed rule’s potential impact on
overall market liquidity and quality. As
discussed in more detail in Parts IV.A.2.
and IV.A.3., the final rule will permit
banking entities to continue to provide
beneficial market-making and
underwriting services to customers, and
therefore provide liquidity to customers
and facilitate capital-raising. However,
the statute upon which the final rule is
based prohibits proprietary trading
activity that is not exempted. As such,
the termination of non-exempt
proprietary trading activities of banking
entities may lead to some general
reductions in liquidity of certain asset
classes. Although the Agencies cannot
say with any certainty, there is good
reason to believe that to a significant
extent the liquidity reductions of this
type may be temporary since the statute
does not restrict proprietary trading
activities of other market participants.86
Thus, over time, non-banking entities
may provide much of the liquidity that
is lost by restrictions on banking
entities’ trading activities. If so,
eventually, the detrimental effects of
increased trading costs, higher costs of
capital, and greater market volatility
should be mitigated.
To respond to concerns raised by
commenters while remaining consistent
with Congressional intent, the final rule
has been modified to provide that
certain purchases and sales are not
Putnam; Wells Fargo (Prop. Trading); Comm. on
Capital Markets Regulation.
84 See, e.g., Rep. Bachus et al.; Members of
Congress (Dec. 2011); Lord Abbett; Morgan Stanley;
Barclays; BoA; Citigroup (Feb. 2012); ABA
(Abernathy); ICSA; SIFMA (Asset Mgmt.) (Feb.
2012); Chamber (Feb. 2012); Putnam; ACLI (Feb.
2012); UBS; Wells Fargo (Prop. Trading); Capital
Group; Sen. Carper et al.; Fidelity; Invesco; Clearing
House Ass’n.; Thakor Study.
85 See, e.g., CalPERS (expressing the belief that a
decline in banking entity proprietary trading will
increase the volatility of the corporate bond market,
especially during times of economic weakness or
periods where risk taking declines, but noting that
portfolio managers have experienced many different
periods of market illiquidity and stating that the
market will adapt post-implementation (e.g.,
portfolio managers will increase their use of CDS
to reduce economic risk to specific bond positions
as the liquidation process of cash bonds takes more
time, alternative market matching networks will be
developed)); Morgan Stanley; Capital Group;
Fidelity; British Bankers’ Ass’n.; Invesco.
86 See David McClean; Public Citizen; Occupy. In
response to commenters who expressed concern
about risks associated with proprietary trading
activities moving to non-banking entities, the
Agencies note that section 13’s prohibition on
proprietary trading and related exemptions apply
only to banking entities. See, e.g., Chamber (Feb.
2012).
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proprietary trading as described in more
detail below.87
a. Definition of ‘‘Trading Account’’
As explained above, section 13
defines proprietary trading as engaging
as principal ‘‘for the trading account of
the banking entity’’ in certain types of
transactions. Section 13(h)(6) of the
BHC Act defines trading account as any
account used for acquiring or taking
positions in financial instruments
principally for the purpose of selling in
the near-term (or otherwise with the
intent to resell in order to profit from
short-term price movements), and any
such other accounts as the Agencies
may, by rule, determine.88
The proposed rule defined trading
account to include three separate
accounts. First, the proposed definition
of trading account included, consistent
with the statute, any account that is
used by a banking entity to acquire or
take one or more covered financial
positions for short-term trading
purposes (the ‘‘short-term trading
account’’).89 The proposed rule
identified four purposes that would
indicate short-term trading intent: (i)
Short-term resale; (ii) benefitting from
actual or expected short-term price
movements; (iii) realizing short-term
arbitrage profits; or (iv) hedging one or
more positions described in (i), (ii) or
(iii). The proposed rule presumed that
an account is a trading account if it is
used to acquire or take a covered
financial position (other than a position
in the market risk rule trading account
or the dealer trading account) that the
banking entity holds for 60 days or
less.90
Second, the proposed definition of
trading account included, for certain
entities, any account that contains
positions that qualify for trading book
capital treatment under the banking
agencies’ market risk capital rules other
than positions that are foreign exchange
derivatives, commodity derivatives or
contracts of sale of a commodity for
delivery (the ‘‘market risk rule trading
account’’).91 ‘‘Covered positions’’ under
the banking agencies’ market-risk
capital rules are positions that are
generally held with the intent of sale in
the short-term.
Third, the proposed definition of
trading account included any account
used by a banking entity that is a
securities dealer, swap dealer, or
final rule § ll.3(d).
12 U.S.C. 1851(h)(6).
89 See proposed rule § ll.3(b)(2)(i)(A).
90 See proposed rule § ll.3(b)(2)(ii).
91 See proposed rule §§ ll.3(b)(2)(i)(B); ll
.3(b)(3).
87 See
88 See
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security-based swap dealer to acquire or
take positions in connection with its
dealing activities (the ‘‘dealer trading
account’’).92 The proposed rule also
included as a trading account any
account used to acquire or take any
covered financial position by a banking
entity in connection with the activities
of a dealer, swap dealer, or securitybased swap dealer outside of the United
States.93 Covered financial positions
held by banking entities that register or
file notice as securities or derivatives
dealers as part of their dealing activity
were included because such positions
are generally held for sale to customers
upon request or otherwise support the
firm’s trading activities (e.g., by hedging
its dealing positions).94
The proposed rule also set forth four
clarifying exclusions from the definition
of trading account. The proposed rule
provided that no account is a trading
account to the extent that it is used to
acquire or take certain positions under
repurchase or reverse repurchase
arrangements, positions under securities
lending transactions, positions for bona
fide liquidity management purposes, or
positions held by derivatives clearing
organizations or clearing agencies.95
Overall, commenters did not raise
significant concerns with or objections
to the short-term trading account.
Several commenters argued that the
definition of trading account should be
limited to only this portion of the
proposed definition of trading
account.96 However, a few commenters
raised concerns regarding the treatment
of arbitrage trading under the proposed
rule.97 Several commenters asserted that
the proposed definition of trading
account was too broad and covered
trading not intended to be covered by
the statute.98 Some of these commenters
maintained that the Agencies exceeded
their statutory authority under section
13 of the BHC Act in defining trading
account to include the market risk rule
trading account and dealer trading
account, and argued that the definition
should be limited to the short-term
trading account definition.99
Commenters argued, for example, that
proposed rule § ll.3(b)(2)(i)(C).
proposed rule § ll.3(b)(2)(i)(C)(5).
94 See Joint Proposal, 76 FR 68,860.
95 See proposed rule § ll.3(b)(2)(iii).
96 See ABA (Keating); JPMC.
97 See AFR et al. (Feb. 2012); Paul Volcker; Credit
Suisse (Seidel); ISDA (Feb. 2012); Japanese Bankers
Ass’n.
98 See ABA (Keating); Allen & Overy (on behalf
of Large Int’l Banks with U.S. Operations); Am.
Express; BoA; Goldman (Prop. Trading); ISDA (Feb.
2012); Japanese Bankers Ass’n.; JPMC; SIFMA et al.
(Prop.Trading) (Feb. 2012); State Street (Feb. 2012).
99 See ABA (Keating); JPMC; SIFMA et al.
(Prop.Trading) (Feb. 2012); State Street (Feb. 2012).
92 See
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93 See
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an overly broad definition of trading
account may cause traditional bank
activities important to safety and
soundness of a banking entity to fall
within the prohibition on proprietary
trading to the detriment of banking
organizations, customers, and financial
markets.100 A number of commenters
suggested modifying and narrowing the
trading account definition to remove the
implicit negative presumption that any
position creates a trading account, or
that all principal trading constitutes
prohibited proprietary trading unless it
qualifies for a narrowly tailored
exemption, and to clearly exempt
activities important to safety and
soundness.101 For example, one
commenter recommended that a
covered financial position be considered
a trading account position only if it
qualifies as a GAAP trading position.102
A few commenters requested the
Agencies define the phrase ‘‘short term’’
in the rule.103
Several commenters argued that the
market risk rule should not be
referenced as part of the definition of
trading account.104 A few of these
commenters argued instead that the
capital treatment of a position be used
only as an indicative factor rather than
a dispositive test.105 One commenter
thought that the market risk rule trading
account was redundant because it
includes only positions that have shortterm trading intent.106 Commenters also
contended that it was difficult to
consider and comment on this aspect of
the proposal because the market risk
capital rules had not been finalized.107
A number of commenters objected to
the dealer trading account prong of the
definition.108 Commenters asserted that
this prong was an unnecessary and
100 See
ABA (Keating); Credit Suisse (Seidel).
ABA (Keating); Ass’n. of Institutional
Investors (Feb. 2012); BoA; Capital Group; IAA;
Credit Suisse (Seidel); ICI (Feb. 2012); ISDA (Feb.
2012); NAIB et al.; SIFMA et al. (Prop.Trading)
(Feb. 2012); SVB; Wellington.
102 See ABA (Keating).
103 See NAIB et al.; Occupy; but See Alfred Brock.
104 See ABA; BoA; Goldman (Prop. Trading);
ISDA (Feb. 2012); JPMC; SIFMA et al.
(Prop.Trading) (Feb. 2012).
105 See BoA; SIFMA et al. (Prop.Trading) (Feb.
2012).
106 See ISDA (Feb. 2012).
107 See ABA (Keating); BoA; Goldman (Prop.
Trading); ISDA (Feb. 2012); JPMC. The banking
agencies adopted a final rule that amends their
respective market risk capital rules on August 30,
2012. See 77 FR 53,060 (Aug. 30, 2012). The
Agencies continued to receive and consider
comments on the proposed rule to implement
section 13 of the BHC Act after that time.
108 See ABA (Keating); Allen & Overy (on behalf
of Large Int’l Banks with U.S. Operations); Am.
Express; Goldman (Prop. Trading); ISDA (Feb.
2012); Japanese Bankers Ass’n.; JPMC; SIFMA et al.
(Prop.Trading) (Feb. 2012).
101 See
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5547
unhelpful addition that went beyond
the requirements of section 13 of the
BHC Act, and that it made the trading
account determination more complex
and difficult.109 In particular,
commenters argued that the dealer
trading account was too broad and
introduced uncertainty because it
presumed that dealers always enter into
positions with short-term intent.110
Commenters also expressed concern
about the difficulty of applying this test
outside the United States and requested
that, if this account is retained, the final
rule be explicit about how it applies to
a swap dealer outside the United States
and treat U.S. swap dealers
consistently.111
In contrast, other commenters
contended that the proposed rule’s
definition of trading account was too
narrow, particularly in its focus on
short-term positions,112 or should be
simplified.113 One commenter argued
that the breadth of the trading account
definition was critical because positions
excluded from the trading account
definition would not be subject to the
proposed rule.114 One commenter
supported the proposed definition of
trading account.115 Other commenters
believed that reference to the marketrisk rule was an important addition to
the definition of trading account. Some
expressed the view that it should
include all market risk capital rule
covered positions and not just those
requiring short-term trading intent.116
Certain commenters proposed
alternate definitions. Several
commenters argued against using the
term ‘‘account’’ and instead advocated
applying the prohibition on proprietary
trading to trading positions.117 Foreign
banks recommended applying the
definition of trading account applicable
to such banks in their home country, if
the home country provided a clear
definition of this term.118 These
commenters argued that new definitions
in the proposed rule, like trading
account, would require foreign banking
109 See ABA (Keating); Allen & Overy (on behalf
of Large Int’l Banks with U.S. Operations); JPMC;
State Street (Feb. 2012); ISDA (Feb. 2012); SIFMA
et al. (Prop.Trading) (Feb. 2012).
110 See ABA (Keating); Am. Express; Goldman
(Prop. Trading); ISDA (Feb. 2012); JPMC.
111 See Allen & Overy (on behalf of Large Int’l
Banks with U.S. Operations); Am. Express; JPMC.
112 See Sens. Merkley & Levin (Feb. 2012);
Occupy.
113 See, e.g., Public Citizen.
114 See AFR et al. (Feb. 2012).
115 See Alfred Brock.
116 See AFR et al. (Feb. 2012).
117 See ABA (Keating); Goldman (Prop. Trading);
NAIB et al.
118 See Japanese Bankers Ass’n.; Norinchukin.
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entities to develop new and complex
procedures and expensive systems.119
Commenters also argued that various
types of trading activities should be
excluded from the trading account
definition. For example, one commenter
asserted that arbitrage trading should
not be considered trading account
activity,120 while other commenters
argued that arbitrage positions and
strategies are proprietary trading and
should be included in the definition of
trading account and prohibited by the
final rule.121 Another commenter argued
that the trading account should include
only positions primarily intended, when
the position is entered into, to profit
from short-term changes in the value of
the assets, and that liquidity
investments that do not have price
changes and that can be sold whenever
the banking entity needs cash should be
excluded from the trading account
definition.122
After carefully reviewing the
comments, the Agencies have
determined to retain in the final rule the
proposed approach for defining trading
account that includes the short-term,
market risk rule, and dealer trading
accounts with modifications to address
issues raised by commenters. The
Agencies believe that this multi-prong
approach is consistent with both the
language and intent of section 13 of the
BHC Act, including the express
statutory authority to include ‘‘any such
other account’’ as determined by the
Agencies.123 The final definition
effectuates Congress’s purpose to
generally focus on short-term trading
while addressing commenters’ desire for
greater certainty regarding the definition
of the trading account.124 In addition,
the Agencies believe commenters’
concerns about the scope of the
proposed definition of trading account
are substantially addressed by the
refined exemptions in the final rule for
customer-oriented activities, such as
market making-related activities, and
the exclusions from proprietary
trading.125 Moreover, the Agencies
119 See
Japanese Bankers Ass’n.
Alfred Brock.
121 See AFR et al. (Feb. 2012); Paul Volcker.
122 See NAIB et al. See infra Part IV.A.1.d.2.
(discussing the liquidity management exclusion).
123 12 U.S.C. 1851(h)(6).
124 In response to commenters’ concerns about the
meaning of account, the Agencies note the term
‘‘trading account’’ is a statutory concept and does
not necessarily refer to an actual account. Trading
account is simply nomenclature for the set of
transactions that are subject to the final rule’s
restrictions on proprietary trading. See ABA
(Keating); Goldman (Prop. Trading); NAIB et al.
125 For example, several commenters’ concerns
about the potential impact of the proposed
definition of trading account were tied to the
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120 See
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believe that it is appropriate to focus on
the economics of a banking entity’s
trading activity to help determine
whether it is engaged in proprietary
trading, as discussed further below.126
As explained above, the short-term
trading prong of the definition largely
incorporates the statutory provisions.
This prong covers trading involving
short-term resale, price movements, and
arbitrage profits, and hedging positions
that result from these activities.
Specifically, the reference to short-term
resale is taken from the statute’s
definition of trading account. The
Agencies continue to believe it is also
appropriate to include in the short-term
trading prong an account that is used by
a banking entity to purchase or sell one
or more financial instruments
principally for the purpose of
benefitting from actual or expected
short-term price movements, realizing
short-term arbitrage profits, or hedging
one or more positions captured by the
short-term trading prong. The
provisions regarding price movements
and arbitrage focus on the intent to
engage in transactions to benefit from
short-term price movements (e.g.,
entering into a subsequent transaction
in the near term to offset or close out,
rather than sell, the risks of a position
held by the banking entity to benefit
from a price movement occurring
between the acquisition of the
underlying position and the subsequent
offsetting transaction) or to benefit from
differences in multiple market prices,
including scenarios where movement in
those prices is not necessary to realize
the intended profit.127 These types of
transactions are economically
equivalent to transactions that are
principally for the purpose of selling in
the near term or with the intent to resell
to profit from short-term price
movements, which are expressly
covered by the statute’s definition of
trading account. Thus, the Agencies
believe it is necessary to include these
provisions in the final rule’s short-term
trading prong to provide clarity about
the scope of the definition and to
prevent evasion of the statute and final
perceived narrowness of the proposed exemptions.
See ABA (Keating); Ass’n. of Institutional Investors
(Feb. 2012); BoA; Capital Group; IAA; Credit Suisse
(Seidel); ICI (Feb. 2012); ISDA (Feb. 2012); NAIB et
al.; SIFMA et al. (Prop. Trading) (Feb. 2012); SVB;
Wellington.
126 See Sens. Merkley & Levin (Feb. 2012).
However, as discussed in this SUPPLEMENTARY
INFORMATION, the Agencies are not prohibiting any
trading that involves profiting from changes in the
value of the asset, as suggested by this commenter,
because permitted activities, such as market
making, can involve price appreciation-related
revenues. See infra Part IV.A.3. (discussing the final
market-making exemption).
127 See Joint Proposal, 76 FR 68,857–68,858.
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rule.128 In addition, like the proposed
rule, the final rule’s short-term trading
prong includes hedging one or more of
the positions captured by this prong
because the Agencies assume that a
banking entity generally intends to hold
the hedging position for only so long as
the underlying position is held.
The remaining two prongs to the
trading account definition apply to
types of entities that engage actively in
trading activities. Each prong focuses on
analogous or parallel short-term trading
activities. A few commenters stated
these prongs were duplicative of the
short-term trading prong, and argued the
Agencies should not include these
prongs in the definition of trading
account, or should only consider them
as non-determinative factors.129 To the
extent that an overlap exists between
the prongs of this definition, the
Agencies believe they are mutually
reinforcing, strengthen the rule’s
effectiveness, and may help simplify the
analysis of whether a purchase or sale
is conducted for the trading account.130
The market risk capital prong covers
trading positions that are covered
positions for purposes of the banking
agency market-risk capital rules, as well
as hedges of those positions. Trading
positions under those rules are positions
held by the covered entity ‘‘for the
purpose of short-term resale or with the
intent of benefitting from actual or
expected short-term price movements,
or to lock-in arbitrage profits.’’ 131 This
definition largely parallels the
provisions of section 13(h)(4) of the
BHC Act and mirrors the short-term
trading account prong of both the
proposed and final rules. Covered
positions are trading positions under the
rule that subject the covered entity to
risks and exposures that must be
actively managed and limited—a
requirement consistent with the
purposes of the section 13 of the BHC
Act.
Incorporating this prong into the
trading account definition reinforces the
consistency between governance of the
types of positions that banking entities
identify as ‘‘trading’’ for purposes of the
market risk capital rules and those that
are trading for purposes of the final rule
under section 13 of the BHC Act.
Moreover, this aspect of the final rule
reduces the compliance burden on
banking entities with substantial trading
128 As a result, the Agencies are not excluding
arbitrage trading from the trading account
definition, as suggested by at least one commenter.
See, e.g., Alfred Brock.
129 See ISDA (Feb. 2012); JPMC; ABA (Keating);
BoA; SIFMA et al. (Prop. Trading) (Feb. 2012).
130 See Occupy.
131 12 CFR part 225, Appendix E.
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activities by establishing a clear, brightline rule for determining that a trade is
within the trading account.132
After reviewing comments, the
Agencies also continue to believe that
financial instruments purchased or sold
by registered dealers in connection with
their dealing activity are generally held
with short-term intent and should be
captured within the trading account.
The Agencies believe the scope of the
dealer prong is appropriate because, as
noted in the proposal, positions held by
a registered dealer in connection with
its dealing activity are generally held for
sale to customers upon request or
otherwise support the firm’s trading
activities (e.g., by hedging its dealing
positions), which is indicative of shortterm intent.133 Moreover, the final rule
includes a number of exemptions for the
activities in which securities dealers,
swap dealers, and security-based swap
dealers typically engage, such as market
making, hedging, and underwriting.
Thus, the Agencies believe the broad
scope of the dealer trading account is
balanced by the exemptions that are
designed to permit dealer entities to
continue to engage in customer-oriented
trading activities, consistent with the
statute. This approach is designed to
ensure that registered dealer entities are
engaged in permitted trading activities,
rather than prohibited proprietary
trading.
The final rule adopts the dealer
trading account substantially as
proposed,134 with streamlining that
eliminates the specific references to
different types of securities and
derivatives dealers. The final rule
adopts the proposed approach to
covering trading accounts of banking
entities that regularly engage in the
business of a dealer, swap dealer, or
security-based swap dealer outside of
the United States. In the case of both
domestic and foreign entities, this
provision applies only to financial
instruments purchased or sold in
connection with the activities that
require the banking entity to be licensed
or registered to engage in the business
of dealing, which is not necessarily all
of the activities of that banking
entity.135 Activities of a banking entity
132 Accordingly, the Agencies are not using a
position’s capital treatment as merely an indicative
factor, as suggested by a few commenters.
133 See Joint Proposal, 76 FR 68,860.
134 See final rule § ll.3(b)(1)(iii).
135 An insured depository institution may be
registered as a swap dealer, but only the swap
dealing activities that require it to be so registered
are covered by the dealer trading account. If an
insured depository institution purchases or sells a
financial instrument in connection with activities of
the insured depository institution that do not trigger
registration as a swap dealer, such as lending,
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that are not covered by the dealer prong
may, however, be covered by the shortterm or market risk rule trading
accounts if the purchase or sale satisfies
the requirements of §§ ll.3(b)(1)(i) or
(ii).136
A few commenters stated that they do
not currently analyze whether a
particular activity would require dealer
registration, so the dealer prong of the
trading account definition would
require banking entities to engage in a
new type of analysis.137 The Agencies
recognize that banking entities that are
registered dealers may not currently
engage in such an analysis with respect
to their current trading activities and,
thus, this may represent a new
regulatory requirement for these
entities. If the regulatory analysis
otherwise engaged in by banking
entities is substantially similar to the
dealer prong analysis required under the
trading account definition, then any
increased compliance burden could be
small or insubstantial.138
In response to commenters’ concerns
regarding the application of this prong
to banking entities acting as dealers in
jurisdictions outside the United
States,139 the Agencies continue to
believe including the activities of a
banking entity engaged in the business
of a dealer, swap dealer, or securitybased swap dealer outside of the United
States, to the extent the instrument is
purchased or sold in connection with
the activities of such business, is
appropriate. As noted above, dealer
activity generally involves short-term
trading. Further, the Agencies are
concerned that differing requirements
for U.S. and foreign dealers may lead to
regulatory arbitrage. For foreign banking
entities acting as dealers outside of the
United States that are eligible for the
exemption for trading conducted by
foreign banking entities, the Agencies
believe the risk-based approach to this
exemption in the final rule should help
deposit-taking, the hedging of business risks, or
other end-user activity, the financial instrument is
included in the trading account only if the
instrument falls within the statutory trading
account under § ll.3(b)(1)(i) or the market risk
rule trading account under § ll.3(b)(1)(ii) of the
final rule.
136 See final rule §§ ll.3(b)(1)(i) and (ii).
137 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Goldman (Prop. Trading).
138 See, e.g., Goldman (Prop. Trading) (‘‘For
instance, a banking entity’s market making-related
activities with respect to credit trading may involve
making a market in bonds (traded in a brokerdealer), single-name CDSs (in a security-based swap
dealer) and CDS indexes (in a swap dealer). For
regulatory or other reasons, these transactions could
take place in different legal entities. . .’’).
139 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; Allen & Overy (on behalf of Large Int’l Banks
with U.S. Operations).
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5549
address the concerns about the scope of
this prong of the definition.140
In response to one commenter’s
suggestion that the Agencies define the
term trading account to allow a foreign
banking entity to use of the relevant
foreign regulator’s definition of this
term, where available, the Agencies are
concerned such an approach could lead
to regulatory arbitrage and otherwise
inconsistent applications of the rule.141
The Agencies believe this commenter’s
general concern about the impact of the
statute and rule on foreign banking
entities’ activities outside the United
States should be substantially addressed
by the exemption for trading conducted
by foreign banking entities under
§ ll.6(e) of the final rule.
Finally, the Agencies have declined to
adopt one commenter’s
recommendation that a position in a
financial instrument be considered a
trading account position only if it
qualifies as a GAAP trading position.142
The Agencies continue to believe that
formally incorporating accounting
standards governing trading securities is
not appropriate because: (i) The
statutory proprietary trading provisions
under section 13 of the BHC Act applies
to financial instruments, such as
derivatives, to which the trading
security accounting standards may not
apply; (ii) these accounting standards
permit companies to classify, at their
discretion, assets as trading securities,
even where the assets would not
otherwise meet the definition of trading
securities; and (iii) these accounting
standards could change in the future
without consideration of the potential
impact on section 13 of the BHC Act
and these rules.143
b. Rebuttable Presumption for the ShortTerm Trading Account
The proposed rule included a
rebuttable presumption clarifying when
a covered financial position, by reason
of its holding period, is traded with
short-term intent for purposes of the
short-term trading account. The
Agencies proposed this presumption
primarily to provide guidance to
banking entities that are not subject to
the market risk capital rules or are not
covered dealers or swap entities and
accordingly may not have experience
evaluating short-term trading intent. In
particular, § __.3(b)(2)(ii) of the
proposed rule provided that an account
would be presumed to be a short-term
trading account if it was used to acquire
final rule § ll.6(e).
Japanese Bankers Ass’n.
142 See ABA (Keating).
143 See Joint Proposal, 76 FR 68,859.
140 See
141 See
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or take a covered financial position that
the banking entity held for a period of
60 days or less.
Several commenters supported the
rebuttable presumption, but suggested
either shortening the holding period to
30 days or less,144 or extending the
period to 90 days,145 to several
months,146 or to one year.147 Some of
these commenters argued that
specifying an overly short holding
period would be contrary to the statute,
invite gamesmanship,148 and miss
speculative positions held for longer
than the specified period.149
Commenters also suggested turning the
presumption into a safe harbor 150 or
into guidance.151
Other commenters opposed the
inclusion of the rebuttable presumption
for a number of reasons and requested
that it be removed.152 For example,
these commenters argued that the
presumption had no statutory basis; 153
was arbitrary; 154 was not supported by
data, facts, or analysis; 155 would
dampen market-making and
underwriting activity; 156 or did not take
into account the nature of trading in
different types of securities.157 Some
commenters also questioned whether
the Agencies would interpret rebuttals
of the presumption consistently,158 and
stressed the difficulty and costliness of
144 See
Japanese Bankers Ass’n.
Capital Group.
146 See AFR et al. (Feb. 2012).
147 See Sens. Merkley & Levin (Feb. 2012); Public
Citizen (arguing that one-year demarks tax law
covering short term capital gains).
148 See Sens. Merkley & Levin (Feb. 2012).
149 See Occupy.
150 See Capital Group.
151 See SIFMA et al. (Prop. Trading) (Feb. 2012).
152 See ABA (Keating); Am. Express; Business
Roundtable; Capital Group; ICI (Feb. 2012);
Investure; JPMC; Liberty Global; STANY; Chamber
(Feb. 2012).
153 See ABA (Keating); JPMC; Chamber (Feb.
2012).
154 See Am. Express; ICI (Feb. 2012).
155 See ABA (Keating); Chamber (Feb. 2012).
156 See AllianceBernstein; Business Roundtable;
ICI (Feb. 2012); Investure; Liberty Global; STANY.
Because the rebuttable presumption does not
impact the availability of the exemptions for
underwriting, market making, and other permitted
activities, the Agencies do not believe this
provision creates any additional burdens on
permissible activities.
157 See Am. Express (noting that most foreign
exchange forward transactions settle in less than
one week and are used as commercial payment
instruments, and not speculative trades); Capital
Group.
158 See ABA (Keating). As discussed below in Part
IV.C., the Agencies expect to continue to coordinate
their supervisory efforts related to section 13 of the
BHC Act and to share information as appropriate in
order to effectively implement the requirements of
that section and the final rule.
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rebutting the presumption,159 such as
enhanced documentation or other
administrative burdens.160 One foreign
banking association also argued that
requiring foreign banking entities to
rebut a U.S. regulatory requirement
would be costly and inappropriate given
that the trading activities of the banking
entity are already reviewed by home
country supervisors.161 This commenter
also contended that the presumption
could be problematic for financial
instruments purchased for long-term
investment purposes that are closed
within 60 days due to market
fluctuations or other changed
circumstances.162
After carefully considering the
comments received, the Agencies
continue to believe the rebuttable
presumption is appropriate to generally
define the meaning of ‘‘short-term’’ for
purposes of the short-term trading
account, especially for small and
regional banking entities that are not
subject to the market risk capital rules
and are not registered dealers or swap
entities. The range of comments the
Agencies received on what ‘‘short-term’’
should mean—from 30 days to one
year—suggests that a clear presumption
would ensure consistency in
interpretation and create a level playing
field for all banking entities with
covered trading activities subject to the
short-term trading account. Based on
their supervisory experience, the
Agencies find that 60 days is an
appropriate cut off for a regulatory
presumption.163 Further, because the
purpose of the rebuttable presumption
is to simplify the process of evaluating
whether individual positions are
included in the trading account, the
Agencies believe that implementing
different holding periods based on the
type of financial instrument would
insert unnecessary complexity into the
presumption.164 The Agencies are not
providing a safe harbor or a reverse
presumption (i.e., a presumption for
positions that are outside of the trading
account), as suggested by some
159 See ABA (Keating); AllianceBernstein; Capital
Group; Japanese Bankers Ass’n.; Liberty Global;
JPMC.
160 See NAIB et al.; Capital Group.
161 See Japanese Bankers Ass’n. As noted above,
the Agencies believe concerns about the impacts of
the definition of trading account on foreign banking
entity trading activity outside of the United States
are substantially addressed by the final rule’s
exemption for proprietary trading conducted by
foreign banking entities in final rule § .6(e).
162 Id.
163 See final rule § .3(b)(2). Commenters did not
provide persuasive evidence of the benefits
associated with a rebuttable presumption for
positions held for greater or fewer than 60 days.
164 See, e.g., Am. Express; Capital Group; Sens.
Merkley & Levin (Feb. 2012).
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commenters, in recognition that some
proprietary trading could occur outside
of the 60 day period.165
Adopting a presumption allows the
Agencies and affected banking entities
to evaluate all the facts and
circumstances surrounding trading
activity in determining whether the
activity implicates the purpose of the
statute. For example, trading in a
financial instrument for long-term
investment that is disposed of within 60
days because of unexpected
developments (e.g., an unexpected
increase in the financial instrument’s
volatility or a need to liquidate the
instrument to meet unexpected liquidity
demands) may not be trading activity
covered by the statute. To reduce the
costs and burdens of rebutting the
presumption, the Agencies will allow a
banking entity to rebut the presumption
for a group of related positions.166
The final rule provides three
clarifying changes to the proposed
rebuttable presumption. First, in
response to comments, the final rule
replaces the reference to an ‘‘account’’
that is presumed to be a trading account
with the purchase or sale of a ‘‘financial
instrument.’’ 167 This change clarifies
that the presumption only applies to the
purchase or sale of a financial
instrument that is held for fewer than 60
days, and not the entire account that is
used to make the purchase or sale.
Second, the final rule clarifies that basis
trades, in which a banking entity buys
one instrument and sells a substantially
similar instrument (or otherwise
transfers the first instrument’s risk), are
subject to the rebuttable
presumption.168 Third, in order to
maintain consistency with definitions
used throughout the final rule, the
references to ‘‘acquire’’ or ‘‘take’’ a
financial position have been replaced
with references to ‘‘purchase’’ or ‘‘sell’’
a financial instrument.169
165 See Capital Group; AFR et al. (Feb. 2012);
Sens. Merkley & Levin (Feb. 2012); Public Citizen;
Occupy.
166 The Agencies believe this should help address
commenters’ concerns about the burdens associated
with rebutting the presumption. See ABA (Keating);
AllianceBernstein; Capital Group; Japanese Bankers
Ass’n.; Liberty Global; JPMC; NAIB et al.; Capital
Group.
167 See, e.g., ABA (Keating); Clearing House
Ass’n.; JPMC.
168 The rebuttable presumption covered these
trades in the proposal, but the final rule’s use of
‘‘financial instrument’’ rather than ‘‘covered
financial position’’ necessitated clarifying this point
in the rule text. See final rule § .3(b)(2). See also
Public Citizen.
169 The Agencies do not believe these revisions
have a substantive effect on the operation or scope
of the final rule in comparison to the statute or
proposed rule.
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c. Definition of ‘‘Financial Instrument’’
Section 13 of the BHC Act generally
prohibits proprietary trading, which is
defined in section 13(h)(4) to mean
engaging as principal for the trading
account in any purchase or sale of any
security, any derivative, any contract of
sale of a commodity for future delivery,
any option on any such security,
derivative, or contract, or any other
security or financial instruments that
the Agencies may, by rule, determine.170
The proposed rule defined the term
‘‘covered financial position’’ to
reference the instruments listed in
section 13(h)(4), including: (i) A
security, including an option on a
security; (ii) a derivative, including an
option on a derivative; or (iii) a contract
of sale of a commodity for future
delivery, or an option on such a
contract.171 To provide additional
clarity, the proposed rule also provided
that, consistent with the statute, any
position that is itself a loan, a
commodity, or foreign exchange or
currency was not a covered financial
position.172
The proposal also defined a number
of other terms used in the definition of
covered financial position, including
commodity, derivative, loan, and
security.173 These terms were generally
defined by reference to the federal
securities laws or the Commodity
Exchange Act because these existing
definitions are generally wellunderstood by market participants and
have been subject to extensive
interpretation in the context of
securities, commodities, and derivatives
trading.
As noted above, the proposed rule
included derivatives within the
definition of covered financial position.
Derivative was defined to include any
swap (as that term is defined in the
Commodity Exchange Act) and securitybased swap (as that term is defined in
the Exchange Act), in each case as
further defined by the CFTC and SEC by
joint regulation, interpretation,
guidance, or other action, in
consultation with the Board pursuant to
section 712(d) of the Dodd-Frank Act.174
The proposed rule also included within
the definition of derivative certain other
transactions that, although not included
within the definition of swap or
security-based swap, also appear to be,
or operate in economic substance as,
12 U.S.C. 1851(h)(4).
proposed rule § .3(c)(3)(i).
172 See proposed rule § .3(c)(3)(ii).
173 See proposed rule § .2(l), (q), (w); § .3(c)(1) and
(2).
174 See 7 U.S.C. 1a(47) (defining ‘‘swap’’); 15
U.S.C. 78c(a)(68) (defining ‘‘security-based swap’’).
derivatives, and which if not included
could permit banking entities to engage
in proprietary trading that is
inconsistent with the purpose of section
13 of the BHC Act. Specifically, the
proposed definition also included: (i)
Any purchase or sale of a nonfinancial
commodity for deferred shipment or
delivery that is intended to be
physically settled; (ii) any foreign
exchange forward or foreign exchange
swap (as those terms are defined in the
Commodity Exchange Act); 175 (iii) any
agreement, contract, or transaction in
foreign currency described in section
2(c)(2)(C)(i) of the Commodity Exchange
Act; 176 (iv) any agreement, contract, or
transactions in a commodity other than
foreign currency described in section
2(c)(2)(D)(i) of the Commodity Exchange
Act; 177 and (v) any transactions
authorized under section 19 of the
Commodity Exchange Act.178 In
addition, the proposed rule excluded
from the definition of derivative (i) any
consumer, commercial, or other
agreement, contract, or transaction that
the CFTC and SEC have further defined
by joint regulation, interpretation,
guidance, or other action as not within
the definition of swap or security-based
swap, and (ii) any identified banking
product, as defined in section 402(b) of
the Legal Certainty for Bank Products
Act of 2000 (7 U.S.C. 27(b)), that is
subject to section 403(a) of that Act (7
U.S.C. 27a(a)).
Commenters expressed a variety of
views regarding the definition of
covered financial position, as well as
other defined terms used in that
definition. For instance, some
commenters argued that the definition
should be expanded to include
transactions in spot commodities or
foreign currency, even though those
instruments are not included by the
statute.179 Other commenters strongly
supported the exclusion of spot
commodity and foreign currency
transactions as consistent with the
statute, arguing that these instruments
are part of the traditional business of
banking and do not represent the types
of instruments that Congress designed
section 13 to address. These
commenters argued that including spot
commodities and foreign exchange
within the definition of covered
financial position in the final rule
would put U.S. banking entities at a
competitive disadvantage and prevent
170 See
171 See
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175 7
U.S.C. 1a(24), (25).
U.S.C. 2(c)(2)(C)(i).
177 7 U.S.C. 2(c)(2)(D)(i).
178 7 U.S.C. 23.
179 See Sens. Merkley & Levin (Feb. 2012); Public
Citizen; Occupy.
176 7
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them from conducting routine banking
operations.180 One commenter argued
that the proposed definition of covered
financial position was effective and
recommended that the definition should
not be expanded.181 Another commenter
argued that an instrument be considered
to be a spot foreign exchange
transaction, and thus not a covered
financial position, if it settles within 5
days of purchase.182 Another
commenter argued that covered
financial positions used in interaffiliate
transactions should expressly be
excluded because they are used for
internal risk management purposes and
not for proprietary trading.183
Some commenters requested that the
final rule exclude additional
instruments from the definition of
covered financial position. For instance,
some commenters requested that the
Agencies exclude commodity and
foreign exchange futures, forwards, and
swaps, arguing that these instruments
typically have a commercial and not
financial purpose and that making them
subject to the prohibitions of section 13
would negatively affect the spot market
for these instruments.184 A few
commenters also argued that foreign
exchange swaps and forwards are used
in many jurisdictions to provide U.S.
dollar-funding for foreign banking
entities and that these instruments
should be excluded since they
contribute to the stability and liquidity
of the market for spot foreign
exchange.185 Other commenters
contended that foreign exchange swaps
and forwards should be excluded
because they are an integral part of
banking entities’ ability to provide trust
and custody services to customers and
are necessary to enable banking entities
to deal in the exchange of currencies for
customers.186
One commenter argued that the
inclusion of certain instruments within
the definition of derivative, such as
purchases or sales of nonfinancial
commodities for deferred shipment or
delivery that are intended to be
physically settled, was inappropriate.187
This commenter alleged that these
instruments are not derivatives but
180 See Northern Trust; Morgan Stanley; JPMC;
Credit Suisse (Seidel); Am. Express; See also AFR
et al. (Feb. 2012) (arguing that the final rule should
explicitly exclude ‘‘spot’’ commodities and foreign
exchange).
181 See Alfred Brock.
182 See Credit Suisse (Seidel).
183 See GE (Feb. 2012).
184 See JPMC; BoA; Citigroup (Feb. 2012).
185 See Govt. of Japan/Bank of Japan; Japanese
Bankers Ass’n.; See also Norinchukin.
186 See Northern Trust; Citigroup (Feb. 2012).
187 See SIFMA et al. (Prop. Trading) (Feb. 2012).
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should instead be viewed as contracts
for purchase of specific commodities to
be delivered at a future date. This
commenter also argued that the
Agencies do not have authority under
section 13 to include these instruments
as ‘‘other securities or financial
instruments’’ subject to the prohibition
on proprietary trading.188
Some commenters also argued that,
because the CFTC and SEC had not yet
finalized their definitions of swap and
security-based swap, it was
inappropriate to use those definitions as
part of the proposed definition of
derivative.189 One commenter argued
that the definition of derivative was
effective, although this commenter
argued that the final rule should not
cross-reference the definition of swap
and security-based swap under the
federal commodities and securities
laws.190
After carefully considering the
comments received on the proposal, the
final rule continues to apply the
prohibition on proprietary trading to the
same types of instruments as listed in
the statute and the proposal, which the
final rule defines as ‘‘financial
instrument.’’ Under the final rule, a
financial instrument is defined as: (i) A
security, including an option on a
security; 191 (ii) a derivative, including
an option on a derivative; or (iii) a
contract of sale of a commodity for
future delivery, or option on a contract
of sale of a commodity for future
delivery.192 The final rule excludes from
the definition of financial instrument: (i)
A loan; 193 (ii) a commodity that is not
an excluded commodity (other than
foreign exchange or currency), a
derivative, a contract of sale of a
commodity for future delivery, or an
option on a contract of sale of a
commodity for future delivery; or (iii)
foreign exchange or currency.194 An
excluded commodity is defined to have
the same meaning as in section 1a(19)
of the Commodity Exchange Act.
The Agencies continue to believe that
these instruments and transactions,
which are consistent with those
referenced in section 13(h)(4) of the
BHC Act as part of the statutory
definition of proprietary trading,
188 See
id.
SIFMA et al. (Prop.Trading) (Feb. 2012);
ISDA (Feb. 2012).
190 See Alfred Brock.
191 The definition of security under the final rule
is the same as under the proposal. See final rule § l
l.2(y).
192 See final rule § .3(c)(1).
193 The definition of loan, as well as comments
received regarding that definition, is discussed in
detail below in Part IV.B.1.c.8.a.
194 See final rule § .3(c)(2).
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189 See
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represent the type of financial
instruments which the proprietary
trading prohibition of section 13 was
designed to cover. While some
commenters requested that this
definition be expanded to include spot
transactions 195 or loans,196 the
Agencies do not believe that it is
appropriate at this time to expand the
scope of instruments subject to the ban
on proprietary trading.197 Similarly,
while some commenters requested that
certain other instruments, such as
foreign exchange swaps and forwards,
be excluded from the definition of
financial instrument,198 the Agencies
believe that these instruments appear to
be, or operate in economic substance as,
derivatives (which are by statute
included within the scope of
instruments subject to the prohibitions
of section 13). If these instruments were
not included within the definition of
financial instrument, banking entities
could use them to engage in proprietary
trading that is inconsistent with the
purpose and design of section 13 of the
BHC Act.
As under the proposal, loans,
commodities, and foreign exchange or
currency are not included within the
scope of instruments subject to section
13. The exclusion of these types of
instruments is intended to eliminate
potential confusion by making clear that
the purchase and sale of loans,
commodities, and foreign exchange or
currency—none of which are referred to
in section 13(h)(4) of the BHC Act—are
outside the scope of transactions to
which the proprietary trading
restrictions apply. For example, the spot
purchase of a commodity would meet
the terms of the exclusion, but the
acquisition of a futures position in the
same commodity would not qualify for
the exclusion.
The final rule also adopts the
definitions of security and derivative as
proposed.199 These definitions, which
195 See Sens. Merkley & Levin (Feb. 2012); Public
Citizen; Occupy.
196 See Occupy.
197 Several commenters supported the exclusion
of spot commodity and foreign currency
transactions as consistent with the statute. See
Northern Trust; Morgan Stanley; State Street (Feb.
2012); JPMC; Credit Suisse (Seidel); Am. Express;
See also AFR et al. (Feb. 2012) (arguing that the
final rule should explicitly exclude ‘‘spot’’
commodities and foreign exchange). One
commenter stated that the proposed definition
should not be expanded. See Alfred Brock. With
respect to the exclusion for loans, the Agencies note
this is generally consistent with the rule of statutory
construction regarding the sale and securitization of
loans. See 12 U.S.C. 1851(g)(2).
198 See JPMC; BAC; Citigroup (Feb. 2012); Govt.
of Japan/Bank of Japan; Japanese Bankers Ass’n.;
Northern Trust; See also Norinchukin.
199 See final rule §§ __.2(h), (y).
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reference existing definitions under the
federal securities and commodities
laws, are generally well-understood by
market participants and have been
subject to extensive interpretation in the
context of securities and commodities
trading activities. While some
commenters argued that it would be
inappropriate to use the definition of
swap and security-based swap because
those terms had not yet been finalized
pursuant to public notice and
comment,200 the CFTC and SEC have
subsequently finalized those definitions
after receiving extensive public
comment on the rulemakings.201 The
Agencies believe that this notice and
comment process provided adequate
opportunity for market participants to
comment on and understand those
terms, and as such they are incorporated
in the definition of derivative under this
final rule.
While some commenters requested
that foreign exchange swaps and
forwards be excluded from the
definition of derivative or financial
instrument, the Agencies have not done
so for the reasons discussed above.
However, as explained below in Part
IV.A.1.d., the Agencies note that to the
extent a banking entity purchases or
sells a foreign exchange forward or
swap, or any other financial instrument,
in a manner that meets an exclusion
from proprietary trading, that
transaction would not be considered to
be proprietary trading and thus would
not be subject to the requirements of
section 13 of the BHC Act and the final
rule. This includes, for instance, the
purchase or sale of a financial
instrument by a banking entity acting
solely as agent, broker, or custodian, or
the purchase or sale of a security as part
of a bona fide liquidity management
plan.
d. Proprietary Trading Exclusions
The proposed rule contained four
exclusions from the definition of trading
account for categories of transactions
that do not fall within the scope of
section 13 of the BHC Act because they
do not involve short-term trading
activities subject to the statutory
prohibition on proprietary trading.
These exclusions covered the purchase
or sale of a financial instrument under
certain repurchase and reverse
repurchase agreements and securities
lending arrangements, for bona fide
200 See SIFMA et al. (Prop. Trading) (Feb. 2012);
ISDA (Feb. 2012).
201 See CFTC and SEC, Further Definition of
‘‘Swap,’’ ‘‘Security-Based Swap,’’ and ‘‘SecurityBased Swap Agreement’’; Mixed swaps; Security
Based Swap Agreement Recordkeeping, 78 FR
48,208 (Aug. 13, 2012).
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liquidity management purposes, and by
a clearing agency or derivatives clearing
organization in connection with clearing
activities.
As discussed below, the final rule
provides exclusions for the purchase or
sale of a financial instrument under
certain repurchase and reverse
repurchase agreements and securities
lending agreements; for bona fide
liquidity management purposes; by
certain clearing agencies, derivatives
clearing organizations in connection
with clearing activities; by a member of
a clearing agency, derivatives clearing
organization, or designated financial
market utility engaged in excluded
clearing activities; to satisfy existing
delivery obligations; to satisfy an
obligation of the banking entity in
connection with a judicial,
administrative, self-regulatory
organization, or arbitration proceeding;
solely as broker, agent, or custodian;
through a deferred compensation or
similar plan; and to satisfy a debt
previously contracted. After considering
comments on these issues, which are
discussed in more detail below, the
Agencies believe that providing
clarifying exclusions for these nonproprietary activities will likely
promote more cost-effective financial
intermediation and robust capital
formation. Overly narrow exclusions for
these activities would potentially
increase the cost of core banking
services, while overly broad exclusions
would increase the risk of allowing the
types of trades the statute was designed
to prohibit. The Agencies considered
these issues in determining the
appropriate scope of these exclusions.
Because the Agencies do not believe
these excluded activities involve
proprietary trading, as defined by the
statute and the final rule, the Agencies
do not believe it is necessary to use our
exemptive authority in section
13(d)(1)(J) of the BHC Act to deem these
activities a form of permitted
proprietary trading.
1. Repurchase and Reverse Repurchase
Arrangements and Securities Lending
The proposed rule’s definition of
trading account excluded an account
used to acquire or take one or more
covered financial positions that arise
under (i) a repurchase or reverse
repurchase agreement pursuant to
which the banking entity had
simultaneously agreed, in writing at the
start of the transaction, to both purchase
and sell a stated asset, at stated prices,
and on stated dates or on demand with
the same counterparty,202 or (ii) a
202 See
proposed rule § ll.3(b)(2)(iii)(A).
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transaction in which the banking entity
lends or borrows a security temporarily
to or from another party pursuant to a
written securities lending agreement
under which the lender retains the
economic interests of an owner of such
security and has the right to terminate
the transaction and to recall the loaned
security on terms agreed to by the
parties.203 Positions held under these
agreements operate in economic
substance as a secured loan and are not
based on expected or anticipated
movements in asset prices. Accordingly,
these types of transactions do not
appear to be of the type the statutory
definition of trading account was
designed to cover.204
Several commenters expressed
support for these exclusions and
requested that the Agencies expand
them.205 For example, one commenter
requested clarification that all types of
repurchase transactions qualify for the
exclusion.206 Some commenters
requested expanding this exclusion to
cover all positions financed by, or
transactions related to, repurchase and
reverse repurchase agreements.207 Other
commenters requested that the
exclusion apply to all transactions that
are analogous to extensions of credit
and are not based on expected or
anticipated movements in asset prices,
arguing that the exclusion would be too
limited in scope to achieve its objective
if it is based on the legal form of the
underlying contract.208 Additionally,
some commenters suggested expanding
the exclusion to cover transactions that
are for funding purposes, including
prime brokerage transactions, or for the
purpose of asset-liability
management.209 Commenters also
recommended expanding the exclusion
to include re-hypothecation of customer
203 See proposed rule § __.3(b)(2)(iii)(B). The
language that described securities lending
transactions in the proposed rule generally mirrored
that contained in Rule 3a5–3 under the Exchange
Act. See 17 CFR 240.3a5–3.
204 See Joint Proposal, 76 FR 68,862.
205 See generally ABA (Keating); Alfred Brock;
Citigroup (Feb. 2012); GE (Feb. 2012); Goldman
(Prop. Trading); ICBA; Japanese Bankers Ass’n.;
JPMC; Norinchukin; RBC; RMA; SIFMA et al. (Prop.
Trading) (Feb. 2012); State Street (Feb. 2012); T.
Rowe Price; UBS; Wells Fargo (Prop. Trading). See
infra Part IV.A.d.10. for the discussion of
commenters’ requests for additional exclusions
from the trading account.
206 See SIFMA et al. (Prop.Trading) (Feb. 2012).
207 See FIA; SIFMA et al. (Prop. Trading) (Feb.
2012).
208 See Goldman (Prop. Trading); JPMC; UBS.
209 See Goldman (Prop. Trading); UBS. For
example, one commenter suggested that fully
collateralized swap transactions should be
exempted from the definition of trading account
because they serve as funding transactions and are
economically similar to repurchase agreements. See
SIFMA et al. (Prop. Trading) (Feb. 2012).
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securities, which can produce financing
structures that, like a repurchase
agreement, are functionally loans.210
In contrast, other commenters argued
that there was no statutory or policy
justification for excluding repurchase
and reverse repurchase agreements from
the trading account, and requested that
this exclusion be removed from the final
rule.211 Some of these commenters
argued that repurchase agreements
could be used for prohibited proprietary
trading 212 and suggested that, if
repurchase agreements are excluded
from the trading account,
documentation detailing the use of
liquidity derived from repurchase
agreements should be required.213 These
commenters suggested that unless the
liquidity is used to secure a position for
a willing customer, repurchase
agreements should be regarded as a
strong indicator of proprietary
trading.214 As an alternative,
commenters suggested that the Agencies
instead use their exemptive authority
pursuant to section 13(d)(1)(J) of the
BHC Act to permit repurchase and
reverse repurchase transactions so that
such transactions must comply with the
statutory limits on material conflicts of
interests and high-risks assets and
trading strategies, and compliance
requirements under the final rule.215
These commenters urged the Agencies
to specify permissible collateral types,
haircuts, and contract terms for
securities lending agreements and
require that the investment of proceeds
from securities lending transactions be
limited to high-quality liquid assets in
order to limit potential risks of these
activities.216
After considering the comments
received, the Agencies have determined
to exclude repurchase and reverse
repurchase agreements and securities
lending agreements from the definition
of proprietary trading under the final
rule. The final rule defines these terms
subject to the same conditions as were
in the proposal. This determination
recognizes that repurchase and reverse
repurchase agreements and securities
lending agreements excluded from the
definition operate in economic
substance as secured loans and do not
in normal practice represent proprietary
210 See
Goldman (Prop. Trading).
AFR et al. (Feb. 2012); Occupy; Public
Citizen; Sens. Merkley & Levin (Feb. 2012).
212 See AFR et al. (Feb. 2012).
213 See Public Citizen.
214 See Public Citizen.
215 See AFR et al. (Feb. 2012); Occupy.
216 See AFR et al. (Feb. 2012); Occupy.
211 See
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trading.217 The Agencies will, however,
monitor these transactions to ensure this
exclusion is not used to engage in
prohibited proprietary trading activities.
To avoid evasion of the rule, the
Agencies note that, in contrast to certain
commenters’ requests,218 only the
transactions pursuant to the repurchase
agreement, reverse repurchase
agreement, or securities lending
agreement are excluded. For example,
the collateral or position that is being
financed by the repurchase or reverse
repurchase agreement is not excluded
and may involve proprietary trading.
The Agencies further note that if a
banking entity uses a repurchase or
reverse repurchase agreement to finance
a purchase of a financial instrument,
other transactions involving that
financial instrument may not qualify for
this exclusion.219 Similarly, short
positions resulting from securities
lending agreements cannot rely upon
this exclusion and may involve
proprietary trading.
Additionally, the Agencies have
determined not to exclude all
transactions, in whatever legal form that
may be construed to be an extension of
credit, as suggested by commenters,
because such a broad exclusion would
be too difficult to assess for compliance
and would provide significant
opportunity for evasion of the
prohibitions in section 13 of the BHC
Act.
2. Liquidity Management Activities
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The proposed definition of trading
account excluded an account used to
acquire or take a position for the
purpose of bona fide liquidity
management, subject to certain
requirements.220 The preamble to the
proposed rule explained that bona fide
liquidity management seeks to ensure
that the banking entity has sufficient,
readily-marketable assets available to
meet its expected near-term liquidity
needs, not to realize short-term profit or
benefit from short-term price
movements.221
217 Congress recognized that repurchase
agreements and securities lending agreements are
loans or extensions of credit by including them in
the legal lending limit. See Dodd–Frank Act section
610 (amending 12 U.S.C. 84b). The Agencies believe
the conditions of the final rule’s exclusions for
repurchase agreements and securities lending
agreements identify those activities that do not in
normal practice represent proprietary trading and,
thus, the Agencies decline to provide additional
requirements for these activities, as suggested by
some commenters. See Public Citizen; AFR et al.
(Feb. 2012); Occupy.
218 See Goldman (Prop. Trading); JPMC; UBS.
219 See CFTC Proposal, 77 FR 8348.
220 See proposed rule § ll.3(b)(2)(iii)(C).
221 Id.
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To curb abuse, the proposed rule
required that a banking entity acquire or
take a position for liquidity management
in accordance with a documented
liquidity management plan that meets
five criteria.222 Moreover, the Agencies
stated in the preamble that liquidity
management positions that give rise to
appreciable profits or losses as a result
of short-term price movements would be
subject to significant Agency scrutiny
and, absent compelling explanatory
facts and circumstances, would be
considered proprietary trading.223
The Agencies received a number of
comments regarding the exclusion.
Many commenters supported the
exclusion of liquidity management
activities from the definition of trading
account as appropriate and necessary.
At the same time, some commenters
expressed the view that the exclusion
was too narrow and should be replaced
with a broader exclusion permitting
trading activity for asset-liability
management (‘‘ALM’’). Commenters
argued that two aspects of the proposed
rule’s definition of ‘‘trading account’’
would cause ALM transactions to fall
within the prohibition on proprietary
trading—the 60-day rebuttable
presumption and the reference to the
market risk rule trading account.224 For
example, commenters expressed
concern that hedging transactions
associated with a banking entity’s
residential mortgage pipeline and
mortgage servicing rights, and managing
credit risk, earnings at risk, capital,
asset-liability mismatches, and foreign
exchange risks would be among
positions that may be held for 60 days
or less.225 These commenters contended
that the exclusion for liquidity
management and the activity
exemptions for risk-mitigating hedging
and trading in U.S. government
obligations would not be sufficient to
permit a wide variety of ALM
activities.226 These commenters
contended that prohibiting trading for
ALM purposes would be contrary to the
goals of enhancing sound risk
management, the safety and soundness
of banking entities, and U.S. financial
proposed rule § ll.3(b)(2)(iii)(C)(1)–(5).
Joint Proposal, 76 FR 68,862.
224 See ABA (Keating); BoA; CH/ABASA; JPMC.
See supra Part IV.A.1.b. (discussing the rebuttable
presumption under § ll3.(b)(2) of the final rule);
See also supra Part IV.A.1.a. (discussing the market
risk rule trading account under § ll3.(b)(1)(ii) of
the final rule).
225 See CH/ABASA; Wells Fargo (Prop. Trading).
226 See CH/ABASA; JPMC; State Street (Feb.
2012); Wells Fargo (Prop. Trading). See also BaFin/
Deutsche Bundesbank.
222 See
223 See
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stability,227 and would limit banking
entities’ ability to manage liquidity.228
Some commenters argued that the
requirements of the exclusion would not
provide a banking entity with sufficient
flexibility to respond to liquidity needs
arising from changing economic
conditions.229 Some commenters argued
the requirement that any position taken
for liquidity management purposes be
limited to the banking entity’s near-term
funding needs failed to account for
longer-term liquidity management
requirements.230 These commenters
further argued that the requirements of
the liquidity management exclusion
might not be synchronized with the
Basel III framework, particularly with
respect to the liquidity coverage ratio if
‘‘near-term’’ is considered less than 30
days.231
Commenters also requested
clarification on a number of other issues
regarding the exclusion. For example,
one commenter requested clarification
that purchases and sales of U.S.
registered mutual funds sponsored by a
banking entity would be permissible.232
Another commenter requested
clarification that the deposits resulting
from providing custodial services that
are invested largely in high-quality
securities in conformance with the
banking entity’s ALM policy would not
be presumed to be ‘‘short-term trading’’
under the final rule.233 Commenters also
urged that the final rule not prohibit
interaffiliate transactions essential to the
ALM function.234
In contrast, other commenters
supported the liquidity management
exclusion criteria 235 and suggested
tightening these requirements. For
example, one commenter recommended
that the rule require that investments
made under the liquidity management
exclusion consist only of high-quality
liquid assets.236 Other commenters
argued that the exclusion for liquidity
management should be eliminated.237
One commenter argued that there was
no need to provide a special exemption
for liquidity management or ALM
activities given the exemptions for
227 See
BoA; JPMC; RBC.
ABA (Keating); Allen & Overy (on behalf
of Canadian Banks); JPMC; NAIB et al.; State Street
(Feb. 2012); T. Rowe Price.
229 See ABA (Keating); CH/ABASA; JPMC.
230 See ABA (Keating); BoA; CH/ABASA; JPMC.
231 See ABA (Keating); Allen & Overy (on behalf
of Canadian Banks); BoA; CH/ABASA
232 See T. Rowe Price.
233 See State Street (Feb. 2012).
234 See State Street (Feb. 2012); JPMC. See also
Part IV.A.1.d.10. (discussing commenter requests to
exclude inter-affiliate transactions).
235 See AFR et al. (Feb. 2012); Occupy.
236 See Occupy.
237 See Sens. Merkley & Levin (Feb. 2012).
228 See
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trading in government obligations and
risk-mitigating hedging activities.238
After carefully reviewing the
comments received, the Agencies have
adopted the proposed exclusion for
liquidity management with several
important modifications. As limited
below, liquidity management activity
serves the important prudential
purpose, recognized in other provisions
of the Dodd-Frank Act and in rules and
guidance of the Agencies, of ensuring
banking entities have sufficient liquidity
to manage their short-term liquidity
needs.239
To ensure that this exclusion is not
misused for the purpose of proprietary
trading, the final rule imposes a number
of requirements. First, the liquidity
management plan of the banking entity
must be limited to securities (in keeping
with the liquidity management
requirements proposed by the Federal
banking agencies) and specifically
contemplate and authorize the
particular securities to be used for
liquidity management purposes;
describe the amount, types, and risks of
securities that are consistent with the
entity’s liquidity management; and the
liquidity circumstances in which the
particular securities may or must be
used.240 Second, any purchase or sale of
securities contemplated and authorized
by the plan must be principally for the
purpose of managing the liquidity of the
banking entity, and not for the purpose
of short-term resale, benefitting from
actual or expected short-term price
movements, realizing short-term
arbitrage profits, or hedging a position
taken for such short-term purposes.
Third, the plan must require that any
securities purchased or sold for
liquidity management purposes be
highly liquid and limited to instruments
the market, credit and other risks of
which the banking entity does not
reasonably expect to give rise to
appreciable profits or losses as a result
of short-term price movements.241
238 See
Sens. Merkley & Levin (Feb. 2012).
section 165(b)(1)(A)(ii) of the Dodd-Frank
Act; Enhanced Prudential Standards, 77 FR 644 at
645 (Jan. 5, 2012), available at https://www.gpo.gov/
fdsys/pkg/FR-2012-01-05/pdf/2011-33364.pdf; See
also Enhanced Prudential Standards, 77 FR 76,678
at 76,682 (Dec. 28, 2012), available at https://
www.gpo.gov/fdsys/pkg/FR-2012-12-28/pdf/201230734.pdf.
240 To ensure sufficient flexibility to respond to
liquidity needs arising from changing economic
times, a banking entity should envision and address
a range of liquidity circumstances in its liquidity
management plan, and provide a mechanism for
periodically reviewing and revising the liquidity
management plan.
241 The requirement to use highly liquid
instruments is consistent with the focus of the
clarifying exclusion on a banking entity’s near-term
liquidity needs. Thus, the final rules do not include
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Fourth, the plan must limit any
securities purchased or sold for
liquidity management purposes to an
amount that is consistent with the
banking entity’s near-term funding
needs, including deviations from
normal operations of the banking entity
or any affiliate thereof, as estimated and
documented pursuant to methods
specified in the plan.242 Fifth, the
banking entity must incorporate into its
compliance program internal controls,
analysis and independent testing
designed to ensure that activities
undertaken for liquidity management
purposes are conducted in accordance
with the requirements of the final rule
and the entity’s liquidity management
plan. Finally, the plan must be
consistent with the supervisory
requirements, guidance and
expectations regarding liquidity
management of the Agency responsible
for regulating the banking entity.
The final rule retains the provision
that the financial instruments purchased
and sold as part of a liquidity
management plan be highly liquid and
not reasonably expected to give rise to
appreciable profits or losses as a result
of short-term price movements. This
requirement is consistent with the
Agencies’ expectation for liquidity
management plans in the supervisory
context. It is not intended to prevent
firms from recognizing profits (or losses)
on instruments purchased and sold for
liquidity management purposes.
Instead, this requirement is intended to
underscore that the purpose of these
transactions must be liquidity
management. Thus, the timing of
purchases and sales, the types and
duration of positions taken and the
incentives provided to managers of
these purchases and sales must all
indicate that managing liquidity, and
not taking short-term profits (or limiting
short-term losses), is the purpose of
these activities.
The exclusion as adopted does not
apply to activities undertaken with the
stated purpose or effect of hedging
aggregate risks incurred by the banking
entity or its affiliates related to assetliability mismatches or other general
market risks to which the entity or
affiliates may be exposed. Further, the
exclusion does not apply to any trading
activities that expose banking entities to
substantial risk from fluctuations in
market values, unrelated to the
management of near-term funding
needs, regardless of the stated purpose
of the activities.243
Overall, the Agencies do not believe
that the final rule will stand as an
obstacle to or otherwise impair the
ability of banking entities to manage the
risks of their businesses and operate in
a safe and sound manner. Banking
entities engaging in bona fide liquidity
management activities generally do not
purchase or sell financial instruments
for the purpose of short-term resale or
to benefit from actual or expected shortterm price movements. The Agencies
have determined, in contrast to certain
commenters’ requests, not to expand
this liquidity management provision to
broadly allow asset-liability
management, earnings management, or
scenario hedging.244 To the extent these
activities are for the purpose of profiting
from short-term price movements or to
hedge risks not related to short-term
funding needs, they represent
proprietary trading subject to section 13
of the BHC Act and the final rule; the
activity would then be permissible only
if it meets all of the requirements for an
exemption, such as the risk-mitigating
hedging exemption, the exemption for
trading in U.S. government securities, or
another exemption.
commenters’ suggested revisions to this
requirement. See Clearing House Ass’n.; See also
Occupy; Sens. Merkley & Levin (Feb. 2012). The
Agencies decline to identify particular types of
securities that will be considered highly liquid for
purposes of the exclusion, as requested by some
commenters, in recognition that such a
determination will depend on the facts and
circumstances. See T. Rowe Price; State Street (Feb.
2012).
242 The Agencies plan to construe ‘‘near-term
funding needs’’ in a manner that is consistent with
the laws, regulations, and issuances related to
liquidity risk management. See, e.g., Liquidity
Coverage Ratio: Liquidity Risk Measurement,
Standards, and Monitoring, 78 FR 71,818 (Nov. 29,
2013); Basel Committee on Bank Supervision, Basel
III: The Liquidity Coverage Ratio and Liquidity Risk
Management Tools (January 2013) available at
https://www.bis.org/publ/bcbs238.htm. The
Agencies believe this should help address
commenters’ concerns about the proposed
requirement. See, e.g., ABA (Keating); Allen &
Overy (on behalf of Canadian Banks); CH/ABASA;
BoA; JPMC.
3. Transactions of Derivatives Clearing
Organizations and Clearing Agencies
A banking entity that is a central
counterparty for clearing and settlement
activities engages in the purchase and
sale of financial instruments as an
integral part of clearing and settling
those instruments. The proposed
definition of trading account excluded
an account used to acquire or take one
or more covered financial positions by
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243 See, e.g., Staff of S. Comm. on Homeland Sec.
& Governmental Affairs Permanent Subcomm. on
Investigations, 113th Cong., Report: JPMorgan
Chase Whale Trades: A Case History of Derivatives
Risks and Abuses (Apr. 11, 2013), available at
https://www.hsgac.senate.gov/download/reportjpmorgan-chase-whale-trades-a-case-history-ofderivatives-risks-and-abuses-march-15–2013.
244 See, e.g., ABA (Keating); BoA; CH/ABASA;
JPMC.
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a derivatives clearing organization
registered under the Commodity
Exchange Act or a clearing agency
registered under the Securities
Exchange Act of 1934 in connection
with clearing derivatives or securities
transactions.245 The preamble to the
proposed rule noted that the purpose of
these transactions is to provide a
clearing service to third parties, not to
profit from short-term resale or shortterm price movements.246
Several commenters supported the
proposed exclusion for derivatives
clearing organizations and urged the
Agencies to expand the exclusion to
cover a banking entity’s clearing-related
activities, such as clearing a trade for a
customer, trading with a clearinghouse,
or accepting positions of a defaulting
member, on grounds that these activities
are not proprietary trades and reduce
systemic risk.247 One commenter
recommended expanding the exclusion
to non-U.S. central counterparties 248 In
contrast, one commenter argued that the
exclusion for derivatives clearing
organizations and clearing agencies had
no statutory basis and should instead be
a permitted activity under section
13(d)(1)(J).249
After considering the comments
received, the final rule retains the
exclusion for purchases and sales of
financial instruments by a banking
entity that is a clearing agency or
derivatives clearing organization in
connection with its clearing
activities.250 In response to
comments,251 the Agencies have also
incorporated two changes to the rule.
First, the final rule applies the exclusion
to the purchase and sale of financial
instruments by a banking entity that is
a clearing agency or derivatives clearing
organization in connection with clearing
financial instrument transactions.
proposed rule § ll.3(b)(2)(iii)(D).
Joint Proposal, 76 FR 68,863.
247 See Allen & Overy (Clearing); Goldman (Prop.
Trading); SIFMA et al. (Prop. Trading) (Feb. 2012);
State Street (Feb. 2012).
248 See IIB/EBF.
249 See Sens. Merkley & Levin (Feb. 2012).
250 ‘‘Clearing agency’’ is defined in the final rule
with reference to the definition of this term in the
Exchange Act. See final rule § ll.3(e)(2).
‘‘Derivatives clearing organization’’ is defined in the
final rule as (i) a derivatives clearing organization
registered under section 5b of the Commodity
Exchange Act; (ii) a derivatives clearing
organization that, pursuant to CFTC regulation, is
exempt from the registration requirements under
section 5b of the Commodity Exchange Act; or (iii)
a foreign derivatives clearing organization that,
pursuant to CFTC regulation, is permitted to clear
for a foreign board of trade that is registered with
the CFTC.
251 See IIB/EBF; BNY Mellon et al.; SIFMA et al.
(Prop.Trading) (Feb. 2012); Allen & Overy
(Clearing); Goldman (Prop. Trading).
245 See
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Second, in response to comments,252 the
exclusion in the final rule is not limited
to clearing agencies or derivatives
clearing organizations that are subject to
SEC or CFTC registration requirements
and, instead, certain foreign clearing
agencies and foreign derivatives clearing
organizations will be permitted to rely
on the exclusion if they are banking
entities.
The Agencies believe that clearing
and settlement activity is not designed
to create short-term trading profits.
Moreover, excluding clearing and
settlement activities prevents the final
rule from inadvertently hindering the
Dodd–Frank Act’s goal of promoting
central clearing of financial
transactions. The Agencies have
narrowly tailored this exclusion by
allowing only central counterparties to
use it and only with respect to their
clearing and settlement activity.
4. Excluded Clearing-Related Activities
of Clearinghouse Members
In addition to the exclusion for
trading activities of a derivatives
clearing organization or clearing agency,
some commenters requested an
additional exclusion from the definition
of ‘‘trading account’’ for clearing-related
activities of members of these
entities.253 These commenters noted
that the proposed definition of ‘‘trading
account’’ provides an exclusion for
positions taken by registered derivatives
clearing organizations and registered
clearing agencies 254 and requested a
corresponding exclusion for certain
clearing-related activities of banking
entities that are members of a clearing
agency or members of a derivatives
clearing organization (collectively,
‘‘clearing members’’).255
Several commenters argued that
certain aspects of the clearing process
may require a clearing member to
engage in principal transactions. For
example, some commenters argued that
a clearinghouse’s default management
process may require clearing members
to take positions in financial
instruments upon default of another
clearing member.256 According to
commenters, default management
processes can involve: (i) Collection of
initial and variation margin from
252 See
IIB/EBF; Allen & Overy (Clearing).
SIFMA et al. (Prop. Trading) (Feb. 2012);
Allen & Overy (Clearing); Goldman (Prop. Trading);
State Street (Feb. 2012).
254 See proposed rule § ll.3(b)(2)(iii)(D).
255 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Allen & Overy (Clearing); Goldman (Prop. Trading);
State Street (Feb. 2012).
256 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Allen & Overy (Clearing); State Street (Feb. 2012).
See also ISDA (Feb. 2012).
253 See
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customers under an ‘‘agency model’’ of
clearing; (ii) porting, where a defaulting
clearing member’s customer positions
and margin are transferred to another
non-defaulting clearing member; 257 (iii)
hedging, where the clearing house looks
to clearing members and third parties to
enter into risk-reducing transactions and
to flatten the market risk associated with
the defaulting clearing member’s house
positions and non-ported customer
positions; (iv) unwinding, where the
defaulting member’s open positions may
be allocated to other clearing members,
affiliates, or third parties pursuant to a
mandatory auction process or forced
allocation; 258 and (v) imposing certain
obligations on clearing members upon
exhaustion of a guaranty fund.259
Commenters argued that, absent an
exclusion from the definition of
‘‘trading account,’’ some of these
clearing-related activities could be
considered prohibited proprietary
trading under the proposal. Two
commenters specifically contended that
the dealer prong of the definition of
‘‘trading account’’ may cause certain of
these activities to be considered
proprietary trading.260 Some
commenters suggested alternative
avenues for permitting such clearingrelated activity under the rules.261
Commenters argued that such clearingrelated activities of banking entities
should not be subject to the rule because
they are risk-reducing, beneficial for the
financial system, required by law under
certain circumstances (e.g., central
clearing requirements for swaps and
security-based swaps under Title VII of
the Dodd-Frank Act), and not used by
banking entities to engage in proprietary
trading.262
Commenters further argued that
certain activities undertaken as part of
a clearing house’s daily risk
management process may be impacted
by the rule, including unwinding selfreferencing transactions through a
mandatory auction (e.g., where a firm
acquired credit default swap (‘‘CDS’’)
protection on itself as a result of a
merger with another firm) 263 and trade
crossing, a mechanism employed by
257 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Allen & Overy (Clearing).
258 See Allen & Overy (Clearing).
259 See SIFMA et al. (Prop. Trading) (Feb. 2012).
260 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(arguing that the SEC has suggested that entities
that collect margins from customers for cleared
swaps may be required to be registered as brokerdealers); State Street (Feb. 2012).
261 See Goldman (Prop. Trading); SIFMA et al.
(Prop.Trading) (Feb. 2012); ISDA (Feb. 2012).
262 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); State Street (Feb. 2012);
Allen & Overy (Clearing).
263 See Allen & Overy (Clearing).
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certain clearing houses to ensure the
accuracy of the price discovery process
in the course of, among other things,
calculating settlement prices and margin
requirements.264
The Agencies do not believe that
certain core clearing-related activities
conducted by a clearing member, often
as required by regulation or the rules
and procedures of a clearing agency,
derivatives clearing organization, or
designated financial market utility,
represent proprietary trading as
contemplated by the statute. For
example, the clearing and settlement
activities discussed above are not
conducted for the purpose of profiting
from short-term price movements. The
Agencies believe that these clearingrelated activities provide important
benefits to the financial system.265 In
particular, central clearing reduces
counterparty credit risk,266 which can
lead to a host of other benefits,
including lower hedging costs,
increased market participation, greater
liquidity, more efficient risk sharing that
promotes capital formation, and
reduced operational risk.267
Accordingly, in response to
comments, the final rule provides that
proprietary trading does not include
specified excluded clearing activities by
a banking entity that is a member of a
264 See Allen & Overy (Clearing); SIFMA et al.
(Prop.Trading) (Feb. 2012). These commenters
stated that, in order to ensure that a clearing
member is providing accurate end-of-day prices for
its open positions, a clearing house may require the
member to provide firm bids for such positions,
which may be tested through a ‘‘forced trade’’ with
another member. See id.; See also ISDA (Feb. 2012).
265 For example, Title VII of the Dodd-Frank Act
mandates the central clearing of swaps and
security-based swaps, and requires that banking
entities that are swap dealers, security-based swap
dealers, major swap participants or major securitybased swap participants collect variation margin
from many counterparties on a daily basis for their
swap or security-based swap activity. See 7 U.S.C.
2(h); 15 U.S.C. 78c–3; 7 U.S.C. 6s(e); 15 U.S.C. 78o–
10(e); Margin Requirements for Uncleared Swaps
for Swap Dealers and Major Swap Participants, 76
FR 23,732 (Apr. 28, 2011). Additionally, the SEC’s
Rule 17Ad–22(d)(11) requires that each registered
clearing agency establish, implement, maintain and
enforce policies and procedures that set forth the
clearing agency’s default management procedures.
See 17 CFR 240.17Ad–22(d)(11). See also Exchange
Act Release No. 68,080 (Oct. 12, 2012), 77 FR
66,220, 66,283 (Nov. 2, 2012).
266 Centralized clearing affects counterparty risk
in three basic ways. First, it redistributes
counterparty risk among members through
mutualization of losses, reducing the likelihood of
sequential counterparty failure and contagion.
Second, margin requirements and monitoring
reduce moral hazard, reducing counterparty risk.
Finally, clearing may reallocate counterparty risk
outside of the clearing agency because netting may
implicitly subordinate outside creditors’ claims
relative to other clearing member claims.
267 See Proposed Rule, Cross-Border SecurityBased Swap Activities, Exchange Act Release No.
69490 (May 1, 2013), 78 FR 30,968, 31,162–31,163
(May 23, 2013).
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clearing agency, a member of a
derivatives clearing organization, or a
member of a designated financial market
utility.268 ‘‘Excluded clearing activities’’
is defined in the rule to identify
particular core clearing-related
activities, many of which were raised by
commenters.269 Specifically, the final
rule will exclude the following activities
by clearing members: (i) Any purchase
or sale necessary to correct error trades
made by or on behalf of customers with
respect to customer transactions that are
cleared, provided the purchase or sale is
conducted in accordance with certain
regulations, rules, or procedures; (ii) any
purchase or sale related to the
management of a default or threatened
imminent default of a customer, subject
to certain conditions, another clearing
member, or the clearing agency,
derivatives clearing organization, or
designated financial market utility
itself; 270 and (iii) any purchase or sale
required by the rules or procedures of a
clearing agency, derivatives clearing
organization, or designated financial
market utility that mitigates risk to such
agency, organization, or utility that
would result from the clearing by a
clearing member of security-based
swaps that references the member or an
affiliate of the member.271
The Agencies are identifying specific
activities in the rule to limit the
potential for evasion that may arise from
a more generalized approach. However,
the relevant supervisory Agencies will
be prepared to provide further guidance
or relief, if appropriate, to ensure that
the terms of the exclusion do not limit
the ability of clearing agencies,
derivatives clearing organizations, or
designated financial market utilities to
effectively manage their risks in
accordance with their rules and
procedures. In response to commenters
requesting that the exclusion be
available when a clearing member is
required by rules of a clearing agency,
derivatives clearing organization, or
designated financial market utility to
purchase or sell a financial instrument
as part of establishing accurate prices to
be used by the clearing agency,
derivatives clearing organization, or
designated financial market utility in its
final rule § ll.3(d)(5).
final rule § ll.3(e)(7).
270 A number of commenters discussed the
default management process and requested an
exclusion for such activities. See SIFMA et al.
(Prop. Trading) (Feb. 2012); Allen & Overy
(Clearing); State Street (Feb. 2012). See also ISDA
(Feb. 2012).
271 See Allen & Overy (Clearing) (discussing rules
that require unwinding self-referencing transactions
through a mandatory auction (e.g., where a firm
acquired CDS protection on itself as a result of a
merger with another firm)).
268 See
269 See
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5557
end of day settlement process,272 the
Agencies note that whether this is an
excluded clearing activity depends on
the facts and circumstances. Similarly,
the availability of other exemptions to
the rule, such as the market-making
exemption, depend on the facts and
circumstances. This exclusion applies
only to excluded clearing activities of
clearing members. It does not permit a
banking entity to engage in proprietary
trading and claim protection for that
activity because trades are cleared or
settled through a central counterparty.
5. Satisfying an Existing Delivery
Obligation
A few commenters requested
additional or expanded exclusions from
the definition of ‘‘trading account’’ for
covering short sales or failures to
deliver.273 These commenters alleged
that a banking entity engages in this
activity for purposes other than to
benefit from short term price
movements and that it is not proprietary
trading as defined in the statute. In
response to these comments, the final
rule provides that a purchase or sale by
a banking entity that satisfies an existing
delivery obligation of the banking entity
or its customers, including to prevent or
close out a failure to deliver, in
connection with delivery, clearing, or
settlement activity is not proprietary
trading.
Among other things, this exclusion
will allow a banking entity that is an
SEC-registered broker-dealer to take
action to address failures to deliver
arising from its own trading activity or
the trading activity of its customers.274
In certain circumstances, SEC-registered
broker-dealers are required to take such
action under SEC rules.275 In addition,
buy-in procedures of a clearing agency,
securities exchange, or national
securities association may require a
272 See Allen & Overy (Clearing); SIFMA et al.
(Prop. Trading) (Feb. 2012); See also ISDA (Feb.
2012).
273 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading).
274 In order to qualify for this exclusion, a
banking entity’s principal trading activity that
results in its own failure to deliver must have been
conducted in compliance with these rules.
275 See, e.g., 17 CFR 242.204 (requiring, among
other things, that a participant of a registered
clearing agency or, upon reasonable allocation, a
broker-dealer for which the participant clears trades
or from which the participant receives trades for
settlement, take action to close out a fail to deliver
position in any equity security by borrowing or
purchasing securities of like kind and quantity); 17
CFR 240.15c3–3(m) (providing that, if a brokerdealer executes a sell order of a customer and does
not obtain possession of the securities from the
customer within 10 business days after settlement,
the broker-dealer must immediately close the
transaction with the customer by purchasing
securities of like kind and quantity).
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banking entity to deliver securities if a
party with a fail to receive position
takes certain action.276 When a banking
entity purchases securities to meet an
existing delivery obligation, it is
engaging in activity that facilitates
timely settlement of securities
transactions and helps provide a
purchaser of the securities with the
benefits of ownership (e.g., voting and
lending rights). In addition, a banking
entity has limited discretion to
determine when and how to take action
to meet an existing delivery
obligation.277 Providing a limited
exclusion for this activity will avoid the
potential for SEC-registered brokerdealers being subject to conflicting or
inconsistent regulatory requirements
with respect to activity required to meet
the broker-dealer’s existing delivery
obligations.
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6. Satisfying an Obligation in
Connection With a Judicial,
Administrative, Self-Regulatory
Organization, or Arbitration Proceeding
The Agencies recognize that, under
certain circumstances, a banking entity
may be required to purchase or sell a
financial instrument at the direction of
a judicial or regulatory body. For
example, an administrative agency or
self-regulatory organization (‘‘SRO’’)
may require a banking entity to
purchase or sell a financial instrument
in the course of disciplinary
proceedings against that banking
entity.278 A banking entity may also be
obligated to purchase or sell a financial
instrument in connection with a judicial
or arbitration proceeding.279 Such
transactions do not represent trading for
276 See, e.g., NSCC Rule 11, NASDAQ Rule 11810,
FINRA Rule 11810.
277 See, e.g., 17 CFR 242.204 (requiring action to
close out a fail to deliver position in an equity
security within certain specified timeframes); 17
CFR 240.15c3–3(m) (requiring a broker-dealer to
‘‘immediately’’ close a transaction under certain
circumstances).
278 For example, an administrative agency or SRO
may require a broker-dealer to offer to buy
securities back from customers where the agency or
SRO finds the broker-dealer fraudulently sold
securities to those customers. See, e.g., In re
Raymond James & Assocs., Exchange Act Release
No. 64767, 101 S.E.C. Docket 1749 (June 29, 2011);
FINRA Dep’t of Enforcement v. Pinnacle Partners
Fin. Corp., Disciplinary Proceeding No.
2010021324501 (Apr. 25, 2012); FINRA Dep’t of
Enforcement v. Fifth Third Sec., Inc., No.
2005002244101 (Press Rel. Apr. 14, 2009).
279 For instance, section 29 of the Exchange Act
may require a broker-dealer to rescind a contract
with a customer that was made in violation of the
Exchange Act. Such rescission relief may involve
the broker-dealer’s repurchase of a financial
instrument from a customer. See 15 U.S.C. 78cc;
Reg’l Props., Inc. v. Fin. & Real Estate Consulting
Co., 678 F.2d 552 (5th Cir. 1982); Freeman v.
Marine Midland Bank N.Y., 419 F.Supp. 440
(E.D.N.Y. 1976).
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short-term profit or gain and do not
constitute proprietary trading under the
statute.
Accordingly, the Agencies have
determined to adopt a provision
clarifying that a purchase or sale of one
or more financial instruments that
satisfies an obligation of the banking
entity in connection with a judicial,
administrative, self-regulatory
organization, or arbitration proceeding
is not proprietary trading for purposes
of these rules. This clarification will
avoid the potential for conflicting or
inconsistent legal requirements for
banking entities.
7. Acting Solely as Agent, Broker, or
Custodian
The proposal clarified that proprietary
trading did not include acting solely as
agent, broker, or custodian for an
unaffiliated third party.280 Commenters
generally supported this aspect of the
proposal. One commenter suggested that
acting as agent, broker, or custodian for
affiliates should be explicitly excluded
from the definition of proprietary
trading in the same manner as acting as
agent, broker, or custodian for
unaffiliated third parties.281
Like the proposal, the final rule
expressly provides that the purchase or
sale of one or more financial
instruments by a banking entity acting
solely as agent, broker, or custodian is
not proprietary trading because acting in
these types of capacities does not
involve trading as principal, which is
one of the requisite aspects of the
statutory definition of proprietary
trading.282 The final rule has been
modified to include acting solely as
agent, broker, or custodian on behalf of
an affiliate. However, the affiliate must
comply with section 13 of the BHC Act
and the final implementing rule; and
may not itself engage in prohibited
proprietary trading. To the extent a
banking entity acts in both a principal
and agency capacity for a purchase or
sale, it may only use this exclusion for
the portion of the purchase or sale for
which it is acting as agent. The banking
entity must use a separate exemption or
proposed rule § ll.3(b)(1).
Japanese Bankers Ass’n.
282 See 12 U.S.C. 1851(h)(4). A common or
collective investment fund that is an investment
company under section 3(c)(3) or 3(c)(11) will not
be deemed to be acting as principal within the
meaning of § ll.3(a) because the fund is
performing a traditional trust activity and purchases
and sells financial instruments solely on behalf of
customers as trustee or in a similar fiduciary
capacity, as evidenced by its regulation under 12
CFR part 9 (Fiduciary Activities of National Banks)
or similar state laws.
280 See
281 See
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exclusion, if applicable, to the extent it
is acting in a principal capacity.
8. Purchases or Sales Through a
Deferred Compensation or Similar Plan
While the proposed rule provided that
the prohibition on covered fund
activities and investments did not apply
to certain instances where the banking
entity acted through or on behalf of a
pension or similar deferred
compensation plan, no such similar
treatment was given for proprietary
trading. One commenter argued that the
proposal restricted a banking entity’s
ability to engage in principal-based
trading as an asset manager that serves
the needs of the institutional investors,
such as through ERISA pension and
401(k) plans.283
To address these concerns, the final
rule provides that proprietary trading
does not include the purchase or sale of
one or more financial instruments
through a deferred compensation, stockbonus, profit-sharing, or pension plan of
the banking entity that is established
and administered in accordance with
the laws of the United States or a foreign
sovereign, if the purchase or sale is
made directly or indirectly by the
banking entity as trustee for the benefit
of the employees of the banking entity
or members of their immediate family.
Banking entities often establish and act
as trustee to pension or similar deferred
compensation plans for their employees
and, as part of managing these plans,
may engage in trading activity. The
Agencies believe that purchases or sales
by a banking entity when acting through
pension and similar deferred
compensation plans generally occur on
behalf of beneficiaries of the plan and
consequently do not constitute the type
of principal trading that is covered by
the statute.
The Agencies note that if a banking
entity engages in trading activity for an
unaffiliated pension or similar deferred
compensation plan, the trading activity
of the banking entity would not be
proprietary trading under the final rule
to the extent the banking entity was
acting solely as agent, broker, or
custodian.
9. Collecting a Debt Previously
Contracted
Several commenters argued that the
final rule should exclude collecting and
disposing of collateral in satisfaction of
debts previously contracted from the
definition of proprietary trading.284
Commenters argued that acquiring and
283 See Ass’n. of Institutional Investors (Nov.
2012).
284 See LSTA (Feb. 2012); JPMC; Goldman (Prop.
Trading); SIFMA et al. (Prop.Trading) (Feb. 2012).
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disposing of collateral in satisfaction of
debt previously contracted does not
involve trading with the intent of
profiting from short-term price
movements and, thus, should not be
proprietary trading for purposes of this
rule. Rather, this activity is a prudent
and desirable part of lending and debt
collection activities.
The Agencies believe that the
purchase and sale of a financial
instrument in satisfaction of a debt
previously contracted does not
constitute proprietary trading. The
Agencies believe an exclusion for
purchases and sales in satisfaction of
debts previously contracted is necessary
for banking entities to continue to lend
to customers, because it allows banking
entities to continue lending activity
with the knowledge that they will not be
penalized for recouping losses should a
customer default. Accordingly, the final
rule provides that proprietary trading
does not include the purchase or sale of
one or more financial instruments in the
ordinary course of collecting a debt
previously contracted in good faith,
provided that the banking entity divests
the financial instrument as soon as
practicable within the time period
permitted or required by the appropriate
financial supervisory agency.285
As a result of this exclusion, banking
entities, including SEC-registered
broker-dealers, will be able to continue
providing margin loans to their
customers and may take possession of
margined collateral following a
customer’s default or failure to meet a
margin call under applicable regulatory
requirements.286 Similarly, a banking
entity that is a CFTC-registered swap
dealer or SEC-registered security-based
swap dealer may take, hold, and
exchange any margin collateral as
counterparty to a cleared or uncleared
swap or security-based swap
transaction, in accordance with the
rules of the Agencies.287 This exclusion
will allow banking entities to comply
with existing regulatory requirements
final rule § ll.3(d)(9).
example, if any margin call is not met in
full within the time required by Regulation T, then
Regulation T requires a broker-dealer to liquidate
securities sufficient to meet the margin call or to
eliminate any margin deficiency existing on the day
such liquidation is required, whichever is less. See
12 CFR 220.4(d).
287 See SEC Proposed Rule, Capital, Margin,
Segregation, Reporting and Recordkeeping
Requirements for Security-Based Swap Dealers,
Exchange Act Release No. 68071, 77 FR 70,214
(Nov. 23, 2012); CFTC Proposed Rule, Margin
Requirements for Uncleared Swaps for Swap
Dealers and Major Swap Participants, 76 FR 23,732
(Apr. 28, 2011); Banking Agencies’ Proposed Rule,
Margin and Capital Requirements for Covered Swap
Entities, 76 FR 27,564 (May 11, 2011).
285 See
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286 For
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regarding the divestiture of collateral
taken in satisfaction of a debt.
10. Other Requested Exclusions
Commenters requested a number of
additional exclusions from the trading
account and, in turn, the prohibition on
proprietary trading. In order to avoid
potential evasion of the final rule, the
Agencies decline to adopt any
exclusions from the trading account
other than the exclusions described
above.288 The Agencies believe that
various modifications to the final rule,
including in particular to the exemption
for market-making related activities,
address many of commenters’ concerns
regarding unintended consequences of
the prohibition on proprietary trading.
2. Section ll.4(a): Underwriting
Exemption
a. Introduction
After carefully considering comments
on the proposed underwriting
exemption, the Agencies are adopting
the proposed underwriting exemption
substantially as proposed, but with
certain refinements and clarifications to
the proposed approach to better reflect
the range of securities offerings that an
underwriter may help facilitate on
behalf of an issuer or selling security
holder and the types of activities an
underwriter may undertake in
connection with a distribution of
securities to facilitate the distribution
process and provide important benefits
to issuers, selling security holders, or
purchasers in the distribution. The
Agencies are adopting such an approach
because the statute specifically permits
banking entities to continue providing
these beneficial services to clients,
customers, and counterparties. At the
same time, to reduce the potential for
evasion of the general prohibition on
proprietary trading, the Agencies are
requiring, among other things, that the
trading desk make reasonable efforts to
sell or otherwise reduce its
288 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (transactions that are not based on expected
or anticipated movements in asset prices, such as
fully collateralized swap transactions that serve
funding purposes); Norinchukin and Wells Fargo
(Prop. Trading) (derivatives that qualify for hedge
accounting); GE (Feb. 2012) (transactions related to
commercial contracts); Citigroup (Feb. 2012) (FX
swaps and FX forwards); SIFMA et al. (Prop.
Trading) (Feb. 2012) (interaffiliate transactions); T.
Rowe Price (purchase and sale of shares in
sponsored mutual funds); RMA (cash collateral
pools); Alfred Brock (arbitrage trading); ICBA
(securities traded pursuant to 12 U.S.C. 1831a(f)).
The Agencies are concerned that these exclusions
could be used to conduct impermissible proprietary
trading, and the Agencies believe some of these
exclusions are more appropriately addressed by
other provisions of the rule. For example,
derivatives qualifying for hedge accounting may be
permitted under the hedging exemption.
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5559
underwriting position (accounting for
the liquidity, maturity, and depth of the
market for the relevant type of security)
and be subject to a robust risk limit
structure that is designed to prevent a
trading desk from having an
underwriting position that exceeds the
reasonably expected near term demands
of clients, customers, or counterparties.
b. Overview
1. Proposed Underwriting Exemption
Section 13(d)(1)(B) of the BHC Act
provides an exemption from the
prohibition on proprietary trading for
the purchase, sale, acquisition, or
disposition of securities and certain
other instruments in connection with
underwriting activities, to the extent
that such activities are designed not to
exceed the reasonably expected near
term demands of clients, customers, or
counterparties.289
Section ll.4(a) of the proposed rule
would have implemented this
exemption by requiring that a banking
entity’s underwriting activities comply
with seven requirements. As discussed
in more detail below, the proposed
underwriting exemption required that:
(i) A banking entity establish a
compliance program under § ll.20;
(ii) the covered financial position be a
security; (iii) the purchase or sale be
effected solely in connection with a
distribution of securities for which the
banking entity is acting as underwriter;
(iv) the banking entity meet certain
dealer registration requirements, where
applicable; (v) the underwriting
activities be designed not to exceed the
reasonably expected near term demands
of clients, customers, or counterparties;
(vi) the underwriting activities be
designed to generate revenues primarily
from fees, commissions, underwriting
spreads, or other income not attributable
to appreciation in the value of covered
financial positions or to hedging of
covered financial positions; and (vii) the
compensation arrangements of persons
performing underwriting activities be
designed not to reward proprietary risktaking.290 The proposal explained that
these seven criteria were proposed so
that any banking entity relying on the
underwriting exemption would be
engaged in bona fide underwriting
activities and would conduct those
activities in a way that would not be
susceptible to abuse through the taking
of speculative, proprietary positions as
289 12
U.S.C. 1851(d)(1)(B).
proposed rule § ll.4(a).
290 See
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part of, or mischaracterized as,
underwriting activity.291
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2. Comments on Proposed Underwriting
Exemption
As a general matter, a few
commenters expressed overall support
for the proposed underwriting
exemption.292 Some commenters
indicated that the proposed exemption
is too narrow and may negatively
impact capital markets.293 As discussed
in more detail below, many commenters
expressed views on the effectiveness of
specific requirements of the proposed
exemption. Further, some commenters
requested clarification or expansion of
the proposed exemption for certain
activities that may be conducted in the
course of underwriting.
Several commenters suggested
alternative approaches to implementing
the statutory exemption for
underwriting activities.294 More
specifically, commenters recommended
that the Agencies: (i) Provide a safe
harbor for low risk, standard
underwritings; 295 (ii) better incorporate
the statutory limitations on high-risk
activity or conflicts of interest; 296 (iii)
prohibit banking entities from
underwriting illiquid securities; 297 (iv)
prohibit banking entities from
participating in private placements; 298
(v) place greater emphasis on adequate
291 See Joint Proposal, 76 FR 68,866; CFTC
Proposal, 77 FR 8352.
292 See Barclays (stating that the proposed
exemption generally effectuates the aims of the
statute while largely avoiding undue interference,
although the commenter also requested certain
technical changes to the rule text); Alfred Brock.
293 See, e.g., Lord Abbett; BoA; Fidelity; Chamber
(Feb. 2012).
294 See Sens. Merkley & Levin (Feb. 2012); BoA;
Fidelity; Occupy; AFR et al. (Feb. 2012).
295 See Sens. Merkley & Levin (Feb. 2012)
(suggesting a safe harbor for underwriting efforts
that meet certain low-risk criteria, including that:
The underwriting be in plain vanilla stock or bond
offerings, including commercial paper, for
established business and governments; and the
distribution be completed within relevant time
periods, as determined by asset classes, with
relevant factors being the size of the issuer and the
market served); Johnson & Prof. Stiglitz (expressing
support for a narrow safe harbor for underwriting
of basic stocks and bonds that raise capital for real
economy firms).
296 See Sens. Merkley & Levin (Feb. 2012)
(suggesting that, for example, the exemption plainly
prevent high-risk, conflict ridden underwritings of
securitizations and structured products and crossreference Section 621 of the Dodd-Frank Act, which
prohibits certain material conflicts of interest in
connection with asset-backed securities).
297 See AFR et al. (Feb. 2012) (recommending that
the Agencies prohibit banking entities from acting
as underwriter for assets classified as Level 3 under
FAS 157, which would prohibit underwriting of
illiquid and opaque securities without a genuine
external market, and representing that such a
restriction would be consistent with the statutory
limitation on exposures to high-risk assets).
298 See Occupy.
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internal compliance and risk
management procedures; 299 or (vi)
make the exemption as broad as
possible.300
3. Final Underwriting Exemption
After considering the comments
received, the Agencies are adopting the
underwriting exemption substantially as
proposed, but with important
modifications to clarify provisions or to
address commenters’ concerns. As
discussed above, some commenters
were generally supportive of the
proposed approach to implementing the
underwriting exemption, but noted
certain areas of concern or uncertainty.
The underwriting exemption the
Agencies are adopting addresses these
issues by further clarifying the scope of
activities that qualify for the exemption.
In particular, the Agencies are refining
the proposed exemption to better
capture the broad range of capitalraising activities facilitated by banking
entities acting as underwriters on behalf
of issuers and selling security holders.
The final underwriting exemption
includes the following components:
• A framework that recognizes the
differences in underwriting activities
across markets and asset classes by
establishing criteria that will be applied
flexibly based on the liquidity, maturity,
and depth of the market for the
particular type of security.
• A general focus on the
‘‘underwriting position’’ held by a
banking entity or its affiliate, and
managed by a particular trading desk, in
connection with the distribution of
securities for which such banking entity
or affiliate is acting as an
underwriter.301
• A definition of the term ‘‘trading
desk’’ that focuses on the functionality
of the desk rather than its legal status,
and requirements that apply at the
trading desk level of organization within
a banking entity or across two or more
affiliates.302
• Five standards for determining
whether a banking entity is engaged in
permitted underwriting activities. Many
299 See BoA (recommending that the Agencies
establish a strong presumption that all of a banking
entity’s activities related to underwriting are
permitted under the rules as long as the banking
entity has adequate compliance and risk
management procedures).
300 See Fidelity (suggested that the rules be
revised to ‘‘provide the broadest exemptions
possible under the statute’’ for underwriting and
certain other permitted activities).
301 See infra Part IV.A.2.c.1.c.
302 See infra Part IV.A.2.c.1.c. The term ‘‘trading
desk’’ is defined in final rule § ll.3(e)(13) as ‘‘the
smallest discrete unit of organization of a banking
entity that purchases or sells financial instruments
for the trading account of the banking entity or an
affiliate thereof.’’
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of these criteria have similarities to
those included in the proposed rule, but
with important modifications in
response to comments. These standards
require that:
Æ The banking entity act as an
‘‘underwriter’’ for a ‘‘distribution’’ of
securities and the trading desk’s
underwriting position be related to such
distribution. The final rule includes
refined definitions of ‘‘distribution’’ and
‘‘underwriter’’ to better capture the
broad scope of securities offerings used
by issuers and selling security holders
and the range of roles that a banking
entity may play as intermediary in such
offerings.303
Æ The amount and types of securities
in the trading desk’s underwriting
position be designed not to exceed the
reasonably expected near term demands
of clients, customers, or counterparties,
and reasonable efforts be made to sell or
otherwise reduce the underwriting
position within a reasonable period,
taking into account the liquidity,
maturity, and depth of the market for
the relevant type of security.304
Æ The banking entity establish,
implement, maintain, and enforce an
internal compliance program that is
reasonably designed to ensure the
banking entity’s compliance with the
requirements of the underwriting
exemption, including reasonably
designed written policies and
procedures, internal controls, analysis,
and independent testing identifying and
addressing:
D The products, instruments, or
exposures each trading desk may
purchase, sell, or manage as part of its
underwriting activities;
D Limits for each trading desk, based
on the nature and amount of the trading
desk’s underwriting activities, including
the reasonably expected near term
demands of clients, customers, or
counterparties, on the amount, types,
and risk of the trading desk’s
underwriting position, level of
exposures to relevant risk factors arising
from the trading desk’s underwriting
position, and period of time a security
may be held;
D Internal controls and ongoing
monitoring and analysis of each trading
desk’s compliance with its limits; and
D Authorization procedures,
including escalation procedures that
require review and approval of any
trade that would exceed a trading desk’s
limit(s), demonstrable analysis of the
basis for any temporary or permanent
303 See final rule §§ ll.4(a)(2)(i), ll.4(a)(3),
ll.4(a)(4); See also infra Part IV.A.2.c.1.c.
304 See final rule § ll.4(a)(2)(ii); See also infra
Part IV.A.2.c.2.c.
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increase to a trading desk’s limit(s), and
independent review of such
demonstrable analysis and approval.305
Æ The compensation arrangements of
persons performing the banking entity’s
underwriting activities are designed not
to reward or incentivize prohibited
proprietary trading.306
Æ The banking entity is licensed or
registered to engage in the activity
described in the underwriting
exemption in accordance with
applicable law.307
After considering commenters’
suggested alternative approaches to
implementing the statute’s underwriting
exemption, the Agencies have
determined to retain the general
structure of the proposed underwriting
exemption. For instance, two
commenters suggested providing a safe
harbor for ‘‘plain vanilla’’ or ‘‘basic’’
underwritings of stocks and bonds.308
The Agencies do not believe that a safe
harbor is necessary to provide certainty
that a banking entity may act as an
underwriter in these particular types of
offerings. This is because ‘‘plain
vanilla’’ or ‘‘basic’’ underwriting
activity should be able to meet the
requirements of the final rule. For
example, the final definition of
‘‘distribution’’ includes any offering of
securities made pursuant to an effective
registration statement under the
Securities Act.309
Further, in response to one
commenter’s request that the final rule
prohibit a banking entity from acting as
an underwriter in illiquid assets that are
determined to not have observable price
inputs under accounting standards,310
the Agencies continue to believe that it
would be inappropriate to incorporate
accounting standards in the rule
because accounting standards could
change in the future without
consideration of the potential impact on
the final rule.311 Moreover, the Agencies
305 See final rule § ll.4(a)(2)(iii); See also infra
Part IV.A.2.c.3.c.
306 See final rule § ll.4(a)(2)(iv); See also infra
Part IV.A.2.c.4.c.
307 See final rule § ll.4(a)(2)(v); See also infra
Part IV.A.2.c.5.c.
308 See Sens. Merkley & Levin (Feb. 2012);
Johnson & Prof. Stiglitz. One of these commenters
also suggested that the Agencies better incorporate
the statutory limitations on material conflicts of
interest and high-risk activities in the underwriting
exemption by including additional provisions in
the exemption to refer to these limitations. See
Sens. Merkley & Levin (Feb. 2012). The Agencies
note that these limitations are adopted in § ll.7
of the final rules, and this provision will apply to
underwriting activities, as well as all other
exempted activities.
309 See final rule § ll.4(a)(3).
310 See AFR et al. (Feb. 2012).
311 See Joint Proposal, 76 FR 68,859 n.101
(explaining why the Agencies declined to
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do not believe it is necessary to
differentiate between liquid and less
liquid securities for purposes of
determining whether a banking entity
may underwrite a distribution of
securities because, in either case, a
banking entity must have a reasonable
expectation of purchaser demand for the
securities and must make reasonable
efforts to sell or otherwise reduce its
underwriting position within a
reasonable period under the final
rule.312
Another commenter suggested that
the Agencies establish a strong
presumption that all of a banking
entity’s activities related to
underwriting are permitted under the
rule as long as the banking entity has
adequate compliance and risk
management procedures.313 While
strong compliance and risk management
procedures are important for banking
entities’ permitted activities, the
Agencies believe that an approach
focused solely on the establishment of a
compliance program would likely
increase the potential for evasion of the
general prohibition on proprietary
trading. Similarly, the Agencies are not
adopting an exemption that is
unlimited, as requested by one
commenter, because the Agencies
believe controls are necessary to prevent
potential evasion of the statute through,
among other things, retaining an unsold
allotment when there is sufficient
customer interest for the securities and
to limit the risks associated with these
activities.314
Underwriters play an important role
in facilitating issuers’ access to funding,
and thus underwriters are important to
the capital formation process and
economic growth.315 Obtaining new
financing can be expensive for an issuer
because of the natural information
advantage that less well-known issuers
have over investors about the quality of
their future investment opportunities.
An underwriter can help reduce these
costs by mitigating the information
asymmetry between an issuer and its
potential investors. The underwriter
does this based in part on its familiarity
with the issuer and other similar issuers
as well as by collecting information
about the issuer. This allows investors
to look to the reputation and experience
5561
of the underwriter as well as its ability
to provide information about the issuer
and the underwriting. For these and
other reasons, most U.S. issuers rely on
the services of an underwriter when
raising funds through public offerings.
As recognized in the statute, the
exemption is intended to permit
banking entities to continue to perform
the underwriting function, which
contributes to capital formation and its
positive economic effects.
c. Detailed Explanation of the
Underwriting Exemption
1. Acting as an Underwriter for a
Distribution of Securities
a. Proposed Requirements That the
Purchase or Sale be Effected Solely in
Connection With a Distribution of
Securities for Which the Banking Entity
Acts as an Underwriter and That the
Covered Financial Position be a Security
Section ll.4(a)(2)(iii) of the
proposed rule required that the
purchase or sale be effected solely in
connection with a distribution of
securities for which a banking entity is
acting as underwriter.316 As discussed
below, the Agencies proposed to define
the terms ‘‘distribution’’ and
‘‘underwriter’’ in the proposed rule. The
proposed rule also required that the
covered financial position being
purchased or sold by the banking entity
be a security.317
i. Proposed Definition of ‘‘Distribution’’
The proposed definition of
‘‘distribution’’ mirrored the definition of
this term used in the SEC’s Regulation
M under the Exchange Act.318 More
specifically, the proposed rule defined
‘‘distribution’’ as ‘‘an offering of
securities, whether or not subject to
registration under the Securities Act,
that is distinguished from ordinary
trading transactions by the magnitude of
the offering and the presence of special
selling efforts and selling methods.’’319
The Agencies did not propose to define
the terms ‘‘magnitude’’ and ‘‘special
selling efforts and selling methods,’’ but
stated that the Agencies would expect to
rely on the same factors considered in
Regulation M for assessing these
elements.320 The Agencies noted that
proposed rule § ll.4(a)(2)(iii).
proposed rule § ll.4(a)(2)(ii).
318 See Joint Proposal, 76 FR 68,866–68,867;
CFTC Proposal, 77 FR 8352; 17 CFR 242.101;
proposed rule § ll.4(a)(3).
319 See proposed rule § ll.4(a)(3).
320 See Joint Proposal, 76 FR 68,867 (‘‘For
example, the number of shares to be sold, the
percentage of the outstanding shares, public float,
and trading volume that those shares represent are
all relevant to an assessment of magnitude. In
316 See
317 See
incorporate certain accounting standards in the
proposed rule); CFTC Proposal, 77 FR 8344 n.107.
312 See infra Part IV.A.2.c.2.c.
313 See BoA.
314 See Fidelity.
315 See, e.g., BoA (‘‘The underwriting activities of
U.S. banking entities are essential to capital
formation and, therefore, economic growth and job
creation.’’); Goldman (Prop. Trading); Sens. Merkley
& Levin (Feb. 2012).
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‘‘magnitude’’ does not imply that a
distribution must be large and,
therefore, this factor would not preclude
small offerings or private placements
from qualifying for the proposed
underwriting exemption.321
ii. Proposed Definition of ‘‘Underwriter’’
Like the proposed definition of
‘‘distribution,’’ the Agencies proposed
to define ‘‘underwriter’’ in a manner
similar to the definition of this term in
the SEC’s Regulation M.322 The
definition of ‘‘underwriter’’ in the
proposed rule was: (i) Any person who
has agreed with an issuer or selling
security holder to: (a) Purchase
securities for distribution; (b) engage in
a distribution of securities for or on
behalf of such issuer or selling security
holder; or (c) manage a distribution of
securities for or on behalf of such issuer
or selling security holder; and (ii) a
person who has an agreement with
another person described in the
preceding provisions to engage in a
distribution of such securities for or on
behalf of the issuer or selling security
holder.323
In connection with this proposed
requirement, the Agencies noted that
the precise activities performed by an
underwriter may vary depending on the
liquidity of the securities being
underwritten and the type of
distribution being conducted. To
determine whether a banking entity is
acting as an underwriter as part of a
distribution of securities, the Agencies
proposed to take into consideration the
extent to which a banking entity is
engaged in the following activities:
• Assisting an issuer in capitalraising;
• Performing due diligence;
• Advising the issuer on market
conditions and assisting in the
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addition, delivering a sales document, such as a
prospectus, and conducting road shows are
generally indicative of special selling efforts and
selling methods. Another indicator of special
selling efforts and selling methods is compensation
that is greater than that for secondary trades but
consistent with underwriting compensation for an
offering.’’); CFTC Proposal, 77 FR 8352; Review of
Antimanipulation Regulation of Securities Offering,
Exchange Act Release No. 33924 (Apr. 19, 1994), 59
FR 21,681, 21,684–21,685 (Apr. 26, 1994).
321 See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8352.
322 See Joint Proposal, 76 FR 68,866–68,867;
CFTC Proposal, 77 FR 8352; 17 CFR 242.101;
proposed rule § ll.4(a)(4).
323 See proposed rule § ll.4(a)(4). As noted in
the proposal, the proposed rule’s definition differed
from the definition in Regulation M because the
proposed rule’s definition would also include a
person who has an agreement with another
underwriter to engage in a distribution of securities
for or on behalf of an issuer or selling security
holder. See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8352.
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preparation of a registration statement
or other offering document;
• Purchasing securities from an
issuer, a selling security holder, or an
underwriter for resale to the public;
• Participating in or organizing a
syndicate of investment banks;
• Marketing securities; and
• Transacting to provide a postissuance secondary market and to
facilitate price discovery.324
The proposal recognized that there may
be circumstances in which an
underwriter would hold securities that
it could not sell in the distribution for
investment purposes. The Agencies
stated that if the unsold securities were
acquired in connection with
underwriting under the proposed
exemption, then the underwriter would
be able to dispose of such securities at
a later time.325
iii. Proposed Requirement That the
Covered Financial Position Be a
Security
Pursuant to § ll.4(a)(2)(ii) of the
proposed exemption, a banking entity
would be permitted to purchase or sell
a covered financial position that is a
security only in connection with its
underwriting activities.326 The proposal
stated that this requirement was meant
to reflect the common usage and
understanding of the term
‘‘underwriting.’’ 327 It was noted,
however, that a derivative or commodity
future transaction may be otherwise
permitted under another exemption
(e.g., the exemptions for market makingrelated or risk-mitigating hedging
activities).328
b. Comments on the Proposed
Requirements That the Trade Be
Effected Solely in Connection With a
Distribution for Which the Banking
Entity Is Acting as an Underwriter and
That the Covered Financial Position Be
a Security
In response to the proposed
requirement that a purchase or sale be
‘‘effected solely in connection with a
distribution of securities’’ for which the
‘‘banking entity is acting as
underwriter,’’ commenters generally
focused on the proposed definitions of
‘‘distribution’’ and ‘‘underwriter’’ and
the types of activities that should be
permitted under the ‘‘in connection
with’’ standard. Commenters did not
324 See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8352.
325 See id.
326 See proposed rule § ll.4(a)(2)(ii).
327 See Joint Proposal, 76 FR 68,866; CFTC
Proposal, 77 FR 8352.
328 See Joint Proposal, 76 FR 68,866 n.132; CFTC
Proposal, 77 FR 8352 n.138.
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directly address the requirement in
§ ll.4(a)(2)(ii) of the proposed rule,
which provided that the covered
financial position purchased or sold
under the exemption must be a security.
A number of commenters expressed
general concern that the proposed
underwriting exemption’s references to
a ‘‘purchase or sale of a covered
financial position’’ could be interpreted
to require compliance with the
proposed rule on a transaction-bytransaction basis. These commenters
indicated that such an approach would
be overly burdensome.329
i. Definition of ‘‘Distribution’’
Several commenters stated that the
proposed definition of ‘‘distribution’’ is
too narrow,330 while one commenter
stated that the proposed definition is too
broad.331 Commenters who viewed the
proposed definition as too narrow stated
that it may exclude important capitalraising and financing transactions that
do not appear to involve ‘‘special selling
efforts and selling methods’’ or
‘‘magnitude.’’ 332 In particular, these
commenters stated that the proposed
definition of ‘‘distribution’’ may
preclude a banking entity from
participating in commercial paper
issuances,333 bridge loans,334 ‘‘at-themarket’’ offerings or ‘‘dribble out’’
programs conducted off issuer shelf
registrations,335 offerings in response to
reverse inquiries,336 offerings through
an automated execution system,337
small private offerings,338 or selling
security holders’ sales of securities of
issuers with large market capitalizations
that are executed as underwriting
transactions in the normal course.339
Several commenters suggested that
the proposed definition be modified to
329 See, e.g., Goldman (Prop. Trading); SIFMA et
al. (Prop. Trading) (Feb. 2012).
330 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading); RBC.
331 See Occupy.
332 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading); RBC.
333 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading). In addition, one commenter expressed
general concern that the proposed rule would cause
a reduction in underwriting services with respect to
commercial paper, which would reduce liquidity in
commercial paper markets and raise the costs of
capital in already tight credit markets. See Chamber
(Feb. 2012).
334 See Goldman (Prop. Trading); Wells Fargo
(Prop. Trading); RBC; LSTA (Feb. 2012).
335 See Goldman (Prop. Trading).
336 See SIFMA et al. (Prop. Trading) (Feb. 2012).
337 See SIFMA et al. (Prop. Trading) (Feb. 2012).
338 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading).
339 See RBC.
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include some or all of these types of
offerings.340 For example, two
commenters requested that the
definition explicitly include all
offerings of securities by an issuer.341
One of these commenters further
requested a broader definition that
would include any offering by a selling
security holder that is registered under
the Securities Act or that involves an
offering document prepared by the
issuer.342 Another commenter suggested
that the rule explicitly authorize certain
forms of offerings, such as offerings
under Rule 144A, Regulation S, Rule
101(b)(10) of Regulation M, or the socalled ‘‘section 4(11⁄2)’’ of the Securities
Act, as well as transactions on behalf of
selling security holders.343 Two
commenters proposed approaches that
would include the resale of notes or
other debt securities received by a
banking entity from a borrower to
replace or refinance a bridge loan.344
One of these commenters stated that
permitting a banking entity to receive
and resell notes or other debt securities
from a borrower to replace or refinance
a bridge loan would preserve the ability
of a banking entity to extend credit and
offer customers a range of financing
options. This commenter further
represented that such an approach
would be consistent with the exclusion
of loans from the proposed definition of
‘‘covered financial position’’ and the
commenter’s recommended exclusion
from the definition of ‘‘trading account’’
for collecting debts previously
contracted.345
340 See Goldman (Prop. Trading); SIFMA et al.
(Prop. Trading) (Feb. 2012); RBC.
341 See Goldman (Prop. Trading) (stating that this
would capture, among other things, commercial
paper issuances, issuer ‘‘dribble out’’ programs, and
small private offerings, which involve the purchase
of securities directly from an issuer with a view
toward resale, but may not always be clearly
distinguished by ‘‘special selling efforts and selling
methods’’ or by ‘‘magnitude’’); SIFMA et al. (Prop.
Trading) (Feb. 2012).
342 See SIFMA et al. (Prop. Trading) (Feb. 2012).
This commenter indicated that expanding the
definition of ‘‘distribution’’ to include both
offerings of securities by an issuer and offerings by
a selling security holder that are registered under
the Securities Act or that involve an offering
document prepared by the issuer would ‘‘include,
for example, an offering of securities by an issuer
or a selling security holder where securities are sold
through an automated order execution system,
offerings in response to reverse inquiries and
commercial paper issuances.’’ Id.
343 See RBC.
344 See Goldman (Prop. Trading); RBC. In
addition, one commenter requested the Agencies
clarify that permitted underwriting activities
include the acquisition and resale of securities
issued in lieu of or to refinance bridge loan
facilities, irrespective of whether such activities
qualify as ‘‘distributions’’ under the proposal. See
LSTA (Feb. 2012).
345 See Goldman (Prop. Trading).
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One commenter, however, stated that
the proposed definition of
‘‘distribution’’ is too broad. This
commenter suggested that the
underwriting exemption should only be
available for registered offerings, and
the rule should preclude a banking
entity from participating in a private
placement. According to the
commenter, permitting a banking entity
to participate in a private placement
may facilitate evasion of the prohibition
on proprietary trading.346
ii. Definition of ‘‘Underwriter’’
Several commenters stated that the
proposed definition of ‘‘underwriter’’ is
too narrow.347 Other commenters,
however, stated that the proposed
definition is too broad, particularly due
to the proposed inclusion of selling
group members.348
Commenters requesting a broader
definition generally stated that the
Agencies should instead use the
Regulation M definition of ‘‘distribution
participant’’ or otherwise revise the
definition of ‘‘underwriter’’ to
incorporate the concept of a
‘‘distribution participant,’’ as defined
under Regulation M.349 According to
these commenters, using the term
‘‘distribution participant’’ would better
reflect current market practice and
would include dealers that participate
in an offering but that do not deal
directly with the issuer or selling
security holder and do not have a
written agreement with the
underwriter.350 One commenter further
represented that the proposed provision
for selling group members may be less
inclusive than the Agencies intended
because individual selling dealers or
dealer groups may or may not have
written agreements with an underwriter
in privity of contract with the issuer.351
Another commenter requested that, if
the ‘‘distribution participant’’ concept is
not incorporated into the rule, the
346 See
Occupy.
SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading).
348 See AFR et al. (Feb. 2012); Public Citizen;
Occupy (suggesting that the Agencies exceeded
their statutory authority by incorporating the
Regulation M definition of ‘‘underwriter,’’ rather
than the Securities Act definition of ‘‘underwriter’’).
349 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading). The term ‘‘distribution participant’’ is
defined in Rule 100 of Regulation M as ‘‘an
underwriter, prospective underwriter, broker,
dealer, or other person who has agreed to
participate or is participating in a distribution.’’ 17
CFR 242.100.
350 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading).
351 See Goldman (Prop. Trading).
347 See
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5563
proposed definition of ‘‘underwriter’’ be
modified to include a person who has
an agreement with an affiliate of an
issuer or selling security holder (e.g., an
agreement with a parent company to
distribute the issuer’s securities).352
Other commenters opposed the
inclusion of selling group members in
the proposed definition of
‘‘underwriter.’’ These commenters
stated that because selling group
members do not provide a price
guarantee to an issuer, they do not
provide services to a customer and their
activities should not qualify for the
underwriting exemption.353
A number of commenters stated that
it is unclear whether the proposed
underwriting exemption would permit a
banking entity to act as an authorized
participant (‘‘AP’’) to an ETF issuer,
particularly with respect to the creation
and redemption of ETF shares or
‘‘seeding’’ an ETF for a short period of
time when it is initially launched.354
For example, a few commenters noted
that APs typically do not perform some
or all of the activities that the Agencies
proposed to consider to help determine
whether a banking entity is acting as an
underwriter in connection with a
distribution of securities, including due
diligence, advising an issuer on market
conditions and assisting in preparation
of a registration statement or offering
documents, and participating in or
organizing a syndicate of investment
banks.355
However, one commenter appeared to
oppose applying the underwriting
exemption to certain AP activities.
According to this commenter, APs are
generally reluctant to concede that they
are statutory underwriters because they
do not perform all the activities
associated with the underwriting of an
operating company’s securities. Further,
this commenter expressed concern that,
if an AP had to rely on the proposed
underwriting exemption, the AP could
be subject to heightened risk of
incurring underwriting liability on the
issuance of ETF shares traded by the
AP. As a result of these considerations,
352 See SIFMA et al. (Prop. Trading) (Feb. 2012).
This commenter also requested a technical
amendment to proposed rule § ll.4(a)(4)(ii) to
clarify that the person is ‘‘participating’’ in a
distribution, not ‘‘engaging’’ in a distribution. See
id.
353 See AFR et al. (Feb. 2012); Public Citizen.
354 See BoA; ICI Global; Vanguard; ICI (Feb.
2012); SSgA (Feb. 2012). As one commenter
explained, an AP may ‘‘seed’’ an ETF for a short
period of time at its inception by entering into
several initial creation transactions with the ETF
issuer and refraining from selling those shares to
investors or redeeming them for a period of time to
facilitate the ETF achieving its liquidity launch
goals. See BoA.
355 See ICI Global; ICI (Feb. 2012); Vanguard.
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the commenter believed that a banking
entity may be less willing to act as an
AP for an ETF issuer if it were required
to rely on the underwriting
exemption.356
iii. ‘‘Solely in Connection With’’
Standard
To qualify for the underwriting
exemption, the proposed rule required a
purchase or sale of a covered financial
position to be effected ‘‘solely in
connection with’’ a distribution of
securities for which the banking entity
is acting as underwriter. Several
commenters expressed concern that the
word ‘‘solely’’ in this provision may
result in an overly narrow interpretation
of permissible activities. In particular,
these commenters indicated that the
‘‘solely in connection with’’ standard
creates uncertainty about certain
activities that are currently conducted
in the course of an underwriting, such
as customary underwriting syndicate
activities.357 One commenter
represented that such activities are
traditionally undertaken to: Support the
success of a distribution; mitigate risk to
issuers, investors, and underwriters; and
facilitate an orderly aftermarket.358 A
few commenters further stated that
requiring a trade to be ‘‘solely’’ in
connection with a distribution by an
underwriter would be inconsistent with
the statute,359 may reduce future
innovation in the capital-raising
process,360 and could create market
disruptions.361
A number of commenters stated that
it is unclear whether certain activities
would qualify for the proposed
underwriting exemption and requested
that the Agencies adopt an exemption
that is broad enough to permit such
activities.362 Commenters stated that
there are a number of activities that
should be permitted under the
underwriting exemption, including: (i)
Creating a naked or covered syndicate
short position in connection with an
offering; 363 (ii) creating a stabilizing
356 See
SSgA (Feb. 2012).
SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); BoA; Wells Fargo (Prop.
Trading); Comm. on Capital Markets Regulation.
358 See Goldman (Prop. Trading).
359 See Goldman (Prop. Trading); Wells Fargo
(Prop. Trading); SIFMA et al. (Prop. Trading) (Feb.
2012).
360 See Goldman (Prop. Trading).
361 See SIFMA et al. (Prop. Trading) (Feb. 2012).
362 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Wells Fargo (Prop.
Trading); RBC.
363 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(‘‘The reason for creating the short positions
(covered and naked) is to facilitate an orderly
aftermarket and to reduce price volatility of newly
offered securities. This provides significant value to
issuers and selling security holders, as well as to
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357 See
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bid; 364 (iii) acquiring positions via
overallotments 365 or trading in the
market to close out short positions in
connection with an overallotment
option or in connection with other
stabilization activities; 366 (iv) using call
spread options in a convertible debt
offering to mitigate dilution of existing
shareholders; 367 (v) repurchasing
existing debt securities of an issuer in
the course of underwriting a new series
of debt securities in order to stimulate
demand for the new issuance; 368 (vi)
purchasing debt securities of
comparable issuers as a price discovery
mechanism in connection with
underwriting a new debt security; 369
(vii) hedging the underwriter’s exposure
to a derivative strategy engaged in with
an issuer; 370 (viii) organizing and
assembling a resecuritized product,
including, for example, sourcing bond
collateral over a period of time in
anticipation of issuing new
securities; 371 and (ix) selling a security
to an intermediate entity as part of the
creation of certain structured
products.372
investors, by giving the syndicate buying power that
helps protect against immediate volatility in the
aftermarket.’’); RBC; Goldman (Prop. Trading).
364 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(‘‘Underwriters may also engage in stabilization
activities under Regulation M by creating a
stabilizing bid to prevent or slow a decline in the
market price of a security. These activities should
be encouraged rather than restricted by the Volcker
Rule because they reduce price volatility and
facilitate the orderly pricing and aftermarket trading
of underwritten securities, thereby contributing to
capital formation.’’).
365 See RBC.
366 See Goldman (Prop. Trading).
367 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading) (stating that the call
spread arrangement ‘‘may make a wider range of
financing options feasible for the issuer of the
convertible debt’’ and ‘‘can help it to raise more
capital at more attractive prices’’).
368 See Wells Fargo (Prop. Trading). The
commenter further stated that the need to purchase
the issuer’s other debt securities from investors may
arise if an investor has limited risk tolerance to the
issuer’s credit or has portfolio restrictions.
According to the commenter, the underwriter
would typically sell the debt securities it purchased
from existing investors to new investors. See id.
369 See Wells Fargo (Prop. Trading).
370 See Goldman (Prop. Trading).
371 See ASF (Feb. 2012) (stating that, for example,
a banking entity may respond to customer or
general market demand for highly-rated mortgage
paper by accumulating residential mortgage-backed
securities over time and holding such securities in
inventory until the transaction can be organized
and assembled).
372 See ICI (Feb. 2012) (stating that the sale of
assets to an intermediate asset-backed commercial
paper or tender option bond program should be
permitted under the underwriting exemption if the
sale is part of the creation of a structured security).
See also AFR et al. (Feb. 2012) (stating that the
treatment of a sale to an intermediate entity should
depend on whether the banking entity or an
external client is the driver of the demand and, if
the banking entity is the driver of the demand, then
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c. Final Requirement That the Banking
Entity Act as an Underwriter for a
Distribution of Securities and the
Trading Desk’s Underwriting Position
Be Related to Such Distribution
The final rule requires that the
banking entity act as an underwriter for
a distribution of securities and the
trading desk’s underwriting position be
related to such distribution.373 This
requirement is substantially similar to
the proposed rule,374 but with five key
refinements. First, to address
commenters’ confusion about whether
the underwriting exemption applies on
a transaction-by-transaction basis, the
phrase ‘‘purchase or sale’’ has been
modified to instead refer to the trading
desk’s ‘‘underwriting position.’’ Second,
to balance this more aggregated
position-based approach, the final rule
specifies that the trading desk is the
organizational level of a banking entity
(or across one or more affiliated banking
entities) at which the requirements of
the underwriting exemption will be
assessed. Third, the Agencies have
made important modifications to the
definition of ‘‘distribution’’ to better
capture the various types of private and
registered offerings a banking entity may
be asked to underwrite by an issuer or
selling security holder. Fourth, the
definition of ‘‘underwriter’’ has been
refined to clarify that both members of
the underwriting syndicate and selling
group members may qualify as
underwriters for purposes of this
exemption. Finally, the word ‘‘solely’’
has been removed to clarify that a
broader scope of activities conducted in
connection with underwriting (e.g.,
stabilization activities) are permitted
under this exemption. These issues are
discussed in turn below.
i. Definition of ‘‘Underwriting Position’’
In response to commenters’ concerns
about transaction-by-transaction
analyses,375 the Agencies are modifying
the near term demand requirement should not be
met). Two commenters stated that the underwriting
exemption should not permit a banking entity to
sell a security to an intermediate entity in the
course of creating a structured product. See
Occupy; Alfred Brock. These commenters were
generally responding to a question on this issue in
the proposal. See Joint Proposal, 76 FR 68,868–
68,869 (question 78); CFTC Proposal, 77 FR 8354
(question 78).
373 Final rule § ll.4(a)(2)(i). The terms
‘‘distribution’’ and ‘‘underwriter’’ are defined in
final rule § ll.4(a)(3) and § ll.4(a)(4),
respectively.
374 Proposed rule § ll.4(a)(2)(iii) required that
‘‘[t]he purchase or sale is effected solely in
connection with a distribution of securities for
which the covered banking entity is acting as
underwriter.’’
375 See, e.g., Goldman (Prop. Trading); SIFMA et
al. (Prop. Trading) (Feb. 2012).
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the exemption to clarify the level at
which compliance with certain
provisions will be assessed. The
proposal was not intended to impose a
transaction-by-transaction approach,
and the final rule’s requirements
generally focus on the long or short
positions in one or more securities held
by a banking entity or its affiliate, and
managed by a particular trading desk, in
connection with a particular
distribution of securities for which such
banking entity or its affiliate is acting as
an underwriter. Like § ll.4(a)(2)(ii) of
the proposed rule, the definition of
‘‘underwriting position’’ is limited to
positions in securities because the
common usage and understanding of the
term ‘‘underwriting’’ is limited to
activities in securities.
A trading desk’s underwriting
position constitutes the securities
positions that are acquired in
connection with a single distribution for
which the relevant banking entity is
acting as an underwriter. A trading desk
may not aggregate securities positions
acquired in connection with two or
more distributions to determine its
‘‘underwriting position.’’ A trading desk
may, however, have more than one
‘‘underwriting position’’ at a particular
point in time if the banking entity is
acting as an underwriter for more than
one distribution. As a result, the
underwriting exemption’s requirements
pertaining to a trading desk’s
underwriting position will apply on a
distribution-by-distribution basis.
A trading desk’s underwriting
position can include positions in
securities held at different affiliated
legal entities, provided the banking
entity is able to provide supervisors or
examiners of any Agency that has
regulatory authority over the banking
entity pursuant to section 13(b)(2)(B) of
the BHC Act with records, promptly
upon request, that identify any related
positions held at an affiliated entity that
are being included in the trading desk’s
underwriting position for purposes of
the underwriting exemption. Banking
entities should be prepared to provide
all records that identify all of the
positions included in a trading desk’s
underwriting position and where such
positions are held.
The Agencies believe that a
distribution-by-distribution approach is
appropriate due to the relatively distinct
nature of underwriting activities for a
single distribution on behalf of an issuer
or selling security holder. The Agencies
do not believe that a narrower
transaction-by-transaction analysis is
necessary to determine whether a
banking entity is engaged in permitted
underwriting activities. The Agencies
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also decline to take a broader approach,
which would allow a banking entity to
aggregate positions from multiple
distributions for which it is acting as an
underwriter, because it would be more
difficult for the banking entity’s internal
compliance personnel and Agency
supervisors and examiners to review the
trading desk’s positions to assess the
desk’s compliance with the
underwriting exemption. A more
aggregated approach would increase the
number of positions in different types of
securities that could be included in the
underwriting position, which would
make it more difficult to determine that
an individual position is related to a
particular distribution of securities for
which the banking entity is acting as an
underwriter and, in turn, increase the
potential for evasion of the general
prohibition on proprietary trading.
ii. Definition of ‘‘Trading Desk’’
The proposed underwriting
exemption would have applied certain
requirements across an entire banking
entity. To promote consistency with the
market-making exemption and address
potential evasion concerns, the final
rule applies the requirements of the
underwriting exemption at the trading
desk level of organization.376 This
approach will result in the requirements
of the underwriting exemption applying
to the aggregate trading activities of a
relatively limited group of employees on
a single desk. Applying requirements at
the trading desk level should facilitate
banking entity and Agency monitoring
and review of compliance with the
exemption by limiting the location
where underwriting activity may occur
and allowing better identification of the
aggregate trading volume that must be
reviewed to determine whether the
desk’s activities are being conducted in
a manner that is consistent with the
underwriting exemption, while also
allowing adequate consideration of the
particular facts and circumstances of the
desk’s trading activities.
The trading desk should be managed
and operated as an individual unit and
should reflect the level at which the
profit and loss of employees engaged in
underwriting activities is attributed. The
term ‘‘trading desk’’ in the underwriting
context is intended to encompass what
is commonly thought of as an
underwriting desk. A trading desk
engaged in underwriting activities
would not necessarily be an active
market participant that engages in
frequent trading activities.
376 See infra Part IV.A.3.c. (discussing the final
market-making exemption).
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A trading desk may manage an
underwriting position that includes
positions held by different affiliated
legal entities.377 Similarly, a trading
desk may include employees working
on behalf of multiple affiliated legal
entities or booking trades in multiple
affiliated entities. The geographic
location of individual traders is not
dispositive for purposes of determining
whether the employees are engaged in
activities for a single trading desk.
iii. Definition of ‘‘Distribution’’
The term ‘‘distribution’’ is defined in
the final rule as: (i) An offering of
securities, whether or not subject to
registration under the Securities Act,
that is distinguished from ordinary
trading transactions by the presence of
special selling efforts and selling
methods; or (ii) an offering of securities
made pursuant to an effective
registration statement under the
Securities Act.378 In response to
comments, the proposed definition has
been revised to eliminate the need to
consider the ‘‘magnitude’’ of an offering
and instead supplements the definition
with an alternative prong for registered
offerings under the Securities Act.379
The proposed definition’s reference to
magnitude caused some commenter
concern with respect to whether it could
be interpreted to preclude a banking
entity from intermediating a small
private placement. After considering
comments, the Agencies have
determined that the requirement to have
special selling efforts and selling
methods is sufficient to distinguish
between permissible securities offerings
and prohibited proprietary trading, and
the additional magnitude factor is not
needed to further this objective.380 As
proposed, the Agencies will rely on the
same factors considered under
Regulation M to analyze the presence of
special selling efforts and selling
377 See
supra note 302 and accompanying text.
rule § ll.4(a)(3).
379 Proposed rule § ll.4(a)(3) defined
‘‘distribution’’ as ‘‘an offering of securities, whether
or not subject to registration under the Securities
Act, that is distinguished from ordinary trading
transactions by the magnitude of the offering and
the presence of special selling efforts and selling
methods.’’
380 The policy goals of this rule differ from those
of the SEC’s Regulation M, which is an antimanipulation rule. The focus on magnitude is
appropriate for that regulation because it helps
identify offerings that can give rise to an incentive
to condition the market for the offered security. To
the contrary, this rule is intended to allow banking
entities to continue to provide client-oriented
financial services, including underwriting services.
The SEC emphasizes that this rule does not have
any impact on Regulation M.
378 Final
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methods.381 Indicators of special selling
efforts and selling methods include
delivering a sales document (e.g., a
prospectus), conducting road shows,
and receiving compensation that is
greater than that for secondary trades
but consistent with underwriting
compensation.382 For purposes of the
final rule, each of these factors need not
be present under all circumstances.
Offerings that qualify as distributions
under this prong of the definition
include, among others, private
placements in which resales may be
made in reliance on the SEC’s Rule
144A or other available exemptions 383
and, to the extent the commercial paper
being offered is a security, commercial
paper offerings that involve the
underwriter receiving special
compensation.384
The Agencies are also adopting a
second prong to this definition, which
will independently capture all offerings
of securities that are made pursuant to
an effective registration statement under
the Securities Act.385 The registration
prong of the definition is intended to
provide another avenue by which an
offering of securities may be conducted
under the exemption, absent other
special selling efforts and selling
methods or a determination of whether
such efforts and methods are being
conducted. The Agencies believe this
prong reduces potential administrative
burdens by providing a bright-line test
for what constitutes a distribution for
purposes of the final rule. In addition,
this prong is consistent with the
purpose and goals of the statute because
it reflects a common type of securities
offering and does not raise evasion
concerns as it is unlikely that an entity
would go through the registration
process solely to facilitate or engage in
381 See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8352.
382 See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8352; Review of Antimanipulation
Regulation of Securities Offering, Exchange Act
Release No. 33924 (Apr. 19, 1994), 59 FR 21,681,
21,684–21,685 (Apr. 26, 1994).
383 The final rule does not provide safe harbors
for particular distribution techniques. A safe
harbor-based approach would provide certainty for
specific types of offerings, but may not account for
evolving market practices and distribution
techniques that could technically satisfy a safe
harbor but that might implicate the concerns that
led Congress to enact section 13 of the BHC Act.
See RBC.
384 This clarification is intended to address
commenters’ concern regarding potential
limitations on banking entities’ ability to facilitate
commercial paper offerings under the proposed
underwriting exemption. See supra Part
IV.A.2.c.1.b.i.
385 See, e.g., Form S–1 (17 CFR 239.11); Form S–
3 (17 CFR 239.13); Form S–8 (17 CFR 239.16b);
Form F–1 (17 CFR 239.31); Form F–3 (17 CFR
239.33).
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speculative proprietary trading.386 This
prong would include, among other
things, the following types of registered
securities offerings: Offerings made
pursuant to a shelf registration
statement (whether on a continuous or
delayed basis),387 bought deals,388 at the
market offerings,389 debt offerings, assetbacked security offerings, initial public
offerings, and other registered offerings.
An offering can be a distribution for
purposes of either § ll.4(a)(3)(i) or
§ ll.4(a)(3)(ii) of the final rule
regardless of whether the offering is
issuer driven, selling security holder
driven, or arises as a result of a reverse
inquiry.390 Provided the definition of
386 Although the Agencies are providing an
additional prong to the definition of ‘‘distribution’’
for registered offerings, the final rule does not limit
the availability of the underwriting exemption to
registered offerings, as suggested by one
commenter. The statute does not include such an
express limitation, and the Agencies decline to
construe the statute to require such an approach. In
response to the commenter stating that permitting
a banking entity to participate in a private
placement may facilitate evasion of the prohibition
on proprietary trading, the Agencies believe this
concern is addressed by the provision in the final
rule requiring that a trading desk have a reasonable
expectation of demand from other market
participants for the amount and type of securities
to be acquired from an issuer or selling security
holder for distribution and make reasonable efforts
to sell its underwriting position within a reasonable
period. As discussed below, the Agencies believe
this requirement in the final rule appropriately
addresses evasion concerns that a banking entity
may retain an unsold allotment for purely
speculative purposes. Further, the Agencies believe
that preventing a banking entity from facilitating a
private offering could unnecessarily hinder capitalraising without providing commensurate benefits
because issuers use private offerings to raise capital
in a variety of situations and the underwriting
exemption’s requirements limit the potential for
evasion for both registered and private offerings, as
noted above.
387 See Securities Offering Reform, Securities Act
Release No. 8591 (July 19, 2005), 70 FR 44,722
(Aug. 3, 2005); 17 CFR 230.405 (defining
‘‘automatic shelf registration statement’’ as a
registration statement filed on Form S–3 (17 CFR
239.13) or Form F–3 (17 CFR 239.33) by a wellknown seasoned issuer pursuant to General
Instruction I.D. or I.C. of such forms, respectively);
17 CFR 230.415.
388 A bought deal is a distribution technique
whereby an underwriter makes a bid for securities
without engaging in a preselling effort, such as book
building or distribution of a preliminary
prospectus. See, e.g., Delayed or Continuous
Offering and Sale of Securities, Securities Act
Release No. 6470 (June 9, 1983), n.5.
389 See, e.g., 17 CFR 230.415(a)(4) (defining ‘‘at
the market offering’’ as ‘‘an offering of equity
securities into an existing trading market for
outstanding shares of the same class at other than
a fixed price’’). At the market offerings may also be
referred to as ‘‘dribble out’’ programs.
390 Under the ‘‘reverse inquiry’’ process, an
investor may be allowed to purchase securities from
the issuer through an underwriter that is not
designated in the prospectus as the issuer’s agent
by having such underwriter approach the issuer
with an interest from the investor. See Joseph
McLaughlin and Charles J. Johnson, Jr., ‘‘Corporate
Finance and the Securities Laws’’ (4th ed. 2006,
supplemented 2012).
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distribution is met, an offering can be a
distribution for purposes of this rule
regardless of how it is conducted,
whether by direct communication,
exchange transactions, or automated
execution system.391
As discussed above, some
commenters expressed concern that the
proposed definition of ‘‘distribution’’
would prevent a banking entity from
acquiring and reselling securities issued
in lieu of or to refinance bridge loan
facilities in reliance on the underwriting
exemption. Bridge financing
arrangements can be structured in many
different ways, depending on the
context and the specific objectives of the
parties involved. As a result, the
treatment of securities acquired in lieu
of or to refinance a bridge loan and the
subsequent sale of such securities under
the final rule depends on the facts and
circumstances. A banking entity may
meet the terms of the underwriting
exemption for its bridge loan activity, or
it may be able to rely on the marketmaking exemption. If the banking
entity’s bridge loan activity does not
qualify for an exemption under the rule,
then it would not be permitted to engage
in such activity.
iv. Definition of ‘‘Underwriter’’
In response to comments, the
Agencies are adopting certain
modifications to the proposed definition
of ‘‘underwriter’’ to better capture
selling group members and to more
closely resemble the definition of
‘‘distribution participant’’ in Regulation
M. In particular, the Agencies are
defining ‘‘underwriter’’ as: (i) A person
who has agreed with an issuer or selling
security holder to: (A) Purchase
securities from the issuer or selling
security holder for distribution; (B)
engage in a distribution of securities for
or on behalf of the issuer or selling
security holder; or (C) manage a
distribution of securities for or on behalf
of the issuer or selling security holder;
or (ii) a person who has agreed to
participate or is participating in a
distribution of such securities for or on
behalf of the issuer or selling security
holder.392
A number of commenters requested
that the Agencies broaden the
underwriting exemption to permit
activities in connection with a
distribution of securities by any
distribution participant. A few of these
commenters interpreted the proposed
definition of ‘‘underwriter’’ as requiring
a selling group member to have a
written agreement with the underwriter
391 See
392 See
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to participate in the distribution.393
These commenters noted that such a
written agreement may not exist under
all circumstances. The Agencies did not
intend to require that members of the
underwriting syndicate or the lead
underwriter have a written agreement
with all selling group members for each
offering or that they be in privity of
contract with the issuer or selling
security holder. To provide clarity on
this issue, the Agencies have modified
the language of subparagraph (ii) of the
definition to include firms that, while
not members of the underwriting
syndicate, have agreed to participate or
are participating in a distribution of
securities for or on behalf of the issuer
or selling security holder.
The final rule does not adopt a
narrower definition of ‘‘underwriter,’’ as
suggested by two commenters.394
Although selling group members do not
have a direct relationship with the
issuer or selling security holder, they do
help facilitate the successful
distribution of securities to a wider
variety of purchasers, such as regional
or retail purchasers that members of the
underwriting syndicate may not be able
to access as easily. Thus, the Agencies
believe it is consistent with the purpose
of the statutory underwriting exemption
and beneficial to recognize and allow
the current market practice of an
underwriting syndicate and selling
group members collectively facilitating
a distribution of securities. The
Agencies note that because banking
entities that are selling group members
will be underwriters under the final
rule, they will be subject to all the
requirements of the underwriting
exemption.
As provided in the preamble to the
proposed rule, engaging in the following
activities may indicate that a banking
entity is acting as an underwriter under
393 The basic documents in firm commitment
underwritten securities offerings generally are: (i)
The agreement among underwriters, which
establishes the relationship among the managing
underwriter, any co-managers, and the other
members of the underwriting syndicate; (ii) the
underwriting (or ‘‘purchase’’) agreement, in which
the underwriters commit to purchase the securities
from the issuer or selling security holder; and (iii)
the selected dealers agreement, in which selling
group members agree to certain provisions relating
to the distribution. See Joseph McLaughlin and
Charles J. Johnson, Jr., ‘‘Corporate Finance and the
Securities Laws’’ (4th ed. 2006, supplemented
2012), Ch. 2. The Agencies understand that two
firms may enter into a master agreement that
governs all offerings in which both firms participate
as members of the underwriting syndicate or as a
member of the syndicate and a selling group
member. See, e.g., SIFMA Master Selected Dealers
Agreement (June 10, 2011), available at
www.sifma.org.
394 See AFR et al. (Feb. 2012); Public Citizen.
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§ ll.4(a)(4) as part of a distribution of
securities:
• Assisting an issuer in capitalraising;
• Performing due diligence;
• Advising the issuer on market
conditions and assisting in the
preparation of a registration statement
or other offering document;
• Purchasing securities from an
issuer, a selling security holder, or an
underwriter for resale to the public;
• Participating in or organizing a
syndicate of investment banks;
• Marketing securities; and
• Transacting to provide a postissuance secondary market and to
facilitate price discovery.395
The Agencies continue to take the view
that the precise activities performed by
an underwriter will vary depending on
the liquidity of the securities being
underwritten and the type of
distribution being conducted. A banking
entity is not required to engage in each
of the above-noted activities to be
considered an underwriter for purposes
of this rule. In addition, the Agencies
note that, to the extent a banking entity
does not meet the definition of
‘‘underwriter’’ in the final rule, it may
be able to rely on the market-making
exemption in the final rule for its
trading activity. In response to
comments noting that APs for ETFs do
not engage in certain of these activities
and inquiring whether an AP would be
able to qualify for the underwriting
exemption for certain of its activities,
the Agencies believe that many AP
activities, such as conducting general
creations and redemptions of ETF
shares, are better suited for analysis
under the market-making exemption
because they are driven by the demands
of other market participants rather than
the issuer, the ETF.396 Whether an AP
may rely on the underwriting exemption
for its activities in an ETF will depend
on the facts and circumstances,
including, among other things, whether
the AP meets the definition of
‘‘underwriter’’ and the offering of ETF
shares qualifies as a ‘‘distribution.’’
To provide further clarity about the
scope of the definition of ‘‘underwriter,’’
the Agencies are defining the terms
‘‘selling security holder’’ and ‘‘issuer’’
in the final rule. The Agencies are using
the definition of ‘‘issuer’’ from the
Securities Act because this definition is
commonly used in the context of
securities offerings and is well
395 See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8352. Post-issuance secondary
market activity is expected to be conducted in
accordance with the market-making exemption.
396 See infra Part IV.A.3.
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5567
understood by market participants.397 A
‘‘selling security holder’’ is defined as
‘‘any person, other than an issuer, on
whose behalf a distribution is made.’’ 398
This definition is consistent with the
definition of ‘‘selling security holder’’
found in the SEC’s Regulation M.399
v. Activities Conducted ‘‘in Connection
With’’ a Distribution
As discussed above, several
commenters expressed concern that the
proposed underwriting exemption
would not allow a banking entity to
engage in certain auxiliary activities that
may be conducted in connection with
acting as an underwriter for a
distribution of securities in the normal
course. These commenters’ concerns
generally arose from the use of the word
‘‘solely’’ in § ll.4(a)(2)(iii) of the
proposed rule, which commenters noted
was not included in the statute’s
underwriting exemption.400 In addition,
a number of commenters discussed
particular activities they believed
should be permitted under the
underwriting exemption and indicated
the term ‘‘solely’’ created uncertainty
about whether such activities would be
permitted.401
To reduce uncertainty in response to
comments, the final rule requires a
trading desk’s underwriting position to
be ‘‘held . . . and managed . . . in
connection with’’ a single distribution
397 See final rule § ll.3(e)(9) (defining the term
‘‘issuer’’ for purposes of the proprietary trading
provisions in subpart B of the final rule). Under
section 2(a)(4) of the Securities Act, ‘‘issuer’’ is
defined as ‘‘every person who issues or proposes to
issue any security; except that with respect to
certificates of deposit, voting-trust certificates, or
collateral-trust certificates, or with respect to
certificates of interest or shares in an
unincorporated investment trust not having a board
of directors (or persons performing similar
functions) or of the fixed, restricted management, or
unit type, the term ‘issuer’ means the person or
persons performing the acts and assuming the
duties of depositor or manager pursuant to the
provisions of the trust or other agreement or
instrument under which such securities are issued;
except that in the case of an unincorporated
association which provides by its articles for
limited liability of any or all of its members, or in
the case of a trust, committee, or other legal entity,
the trustees or members thereof shall not be
individually liable as issuers of any security issued
by the association, trust, committee, or other legal
entity; except that with respect to equipment-trust
certificates or like securities, the term ‘issuer’
means the person by whom the equipment or
property is or is to be used; and except that with
respect to fractional undivided interests in oil, gas,
or other mineral rights, the term ‘issuer’ means the
owner of any such right or of any interest in such
right (whether whole or fractional) who creates
fractional interests therein for the purpose of public
offering.’’ 15 U.S.C. 77b(a)(4).
398 Final rule § ll.4(a)(5).
399 See 17 CFR 242.100(b).
400 See supra Part IV.A.2.c.1.b.iii.
401 See supra notes 357, 358, 363–372 and
accompanying text.
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for which the relevant banking entity is
acting as an underwriter, rather than
requiring that a purchase or sale be
‘‘effected solely in connection with’’
such a distribution. Importantly, for
purposes of establishing an
underwriting position in reliance on the
underwriting exemption, a trading desk
may only engage in activities that are
related to a particular distribution of
securities for which the banking entity
is acting as an underwriter. Activities
that may be permitted under the
underwriting exemption include
stabilization activities,402 syndicate
shorting and aftermarket short
covering,403 holding an unsold
allotment when market conditions may
make it impracticable to sell the entire
allotment at a reasonable price at the
time of the distribution and selling such
position when it is reasonable to do
so,404 and helping the issuer mitigate its
risk exposure arising from the
distribution of its securities (e.g.,
entering into a call-spread option with
an issuer as part of a convertible debt
offering to mitigate dilution to existing
shareholders).405 Such activities should
be intended to effectuate the
distribution process and provide
benefits to issuers, selling security
holders, or purchasers in the
distribution. Existing laws, regulations,
and self-regulatory organization rules
limit or place certain requirements
around many of these activities. For
example, an underwriter’s subsequent
402 See SIFMA et al. (Prop. Trading) (Feb. 2012).
See Anti-Manipulation Rules Concerning Securities
Offerings, Exchange Act Release No. 38067 (Dec. 20,
1996), 62 FR 520, 535 (Jan. 3, 1997) (‘‘Although
stabilization is price-influencing activity intended
to induce others to purchase the offered security,
when appropriately regulated it is an effective
mechanism for fostering an orderly distribution of
securities and promotes the interests of
shareholders, underwriters, and issuers.’’).
403 See SIFMA et al. (Prop. Trading) (Feb. 2012);
RBC; Goldman (Prop. Trading). See Proposed
Amendments to Regulation M: Anti-Manipulation
Rules Concerning Securities Offerings, Exchange
Act Release No. 50831 (Dec. 9, 2004), 69 FR 75,774,
75,780 (Dec. 17, 2004) (‘‘In the typical offering, the
syndicate agreement allows the managing
underwriter to ‘oversell’ the offering, i.e., establish
a short position beyond the number of shares to
which the underwriting commitment relates. The
underwriting agreement with the issuer often
provides for an ‘overallotment option’ whereby the
syndicate can purchase additional shares from the
issuer or selling shareholders in order to cover its
short position. To the extent that the syndicate
short position is in excess of the overallotment
option, the syndicate is said to have taken an
‘uncovered’ short position. The syndicate short
position, up to the amount of the overallotment
option, may be covered by exercising the option or
by purchasing shares in the market once secondary
trading begins.’’).
404 See SIFMA et al. (Prop. Trading) (Feb. 2012);
RBC; BoA; BDA (Feb. 2012).
405 See SIFMA et al. (Prop. Trading) (Feb. 2012);
RBC; Goldman (Prop. Trading).
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sale of an unsold allotment must
comply with applicable provisions of
the federal securities laws and the rules
thereunder. Moreover, any position
resulting from these activities must be
included in the trading desk’s
underwriting position, which is subject
to a number of restrictions in the final
rule. Specifically, as discussed in more
detail below, the trading desk must
make reasonable efforts to sell or
otherwise reduce its underwriting
position within a reasonable period,406
and each trading desk must have robust
limits on, among other things, the
amount, types, and risks of its
underwriting position and the period of
time a security may be held.407 Thus, in
general, the underwriting exemption
would not permit a trading desk, for
example, to acquire a position as part of
its stabilization activities and hold that
position for an extended period.
This approach does not mean that any
activity that is arguably connected to a
distribution of securities is permitted
under the underwriting exemption.
Certain activities noted by commenters
are not core to the underwriting
function and, thus, are not permitted
under the final underwriting exemption.
However, a banking entity may be able
to rely on another exemption for such
activities (e.g., the market-making or
hedging exemptions), if applicable. For
example, a trading desk would not be
able to use the underwriting exemption
to purchase a financial instrument from
a customer to facilitate the customer’s
ability to buy securities in the
distribution.408 Further, purchasing
another financial instrument to help
determine how to price the securities
that are subject to a distribution would
not be permitted under the underwriting
exemption.409 These two activities may
final rule § ll.4(a)(2)(ii); infra Part
IV.A.2.c.2.c. (discussing the requirement to make
reasonable efforts to sell or otherwise reduce the
underwriting position).
407 See final rule § ll.4(a)(2)(iii)(B); infra Part
IV.A.2.c.3.c. (discussing the required limits for
trading desks engaged in underwriting activity).
408 See Wells Fargo (Prop. Trading). The Agencies
do not believe this activity is consistent with
underwriting activity because it could result in an
underwriting desk holding a variety of positions
over time that are not directly related to a
distribution of securities the desk is conducting on
behalf of an issuer or selling security holder.
Further, the Agencies believe this activity may be
more appropriately analyzed under the marketmaking exemption because market makers generally
purchase or sell a financial instrument at the
request of customers and otherwise routinely stand
ready to purchase and sell a variety of related
financial instruments.
409 See id. The Agencies view this activity as
inconsistent with underwriting because
underwriters typically engage in other activities,
such as book-building and other marketing efforts,
to determine the appropriate price for a security
406 See
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be permitted under the market-making
exemption, depending on the facts and
circumstances. In response to one
commenter’s suggestion that hedging
the underwriter’s risk exposure be
permissible under this exemption, the
Agencies emphasize that hedging the
underwriter’s risk exposure is not
permitted under the underwriting
exemption.410 A banking entity must
comply with the hedging exemption for
such activity.
In response to comments about the
sale of a security to an intermediate
entity in connection with a structured
finance product,411 the Agencies have
not modified the underwriting
exemption. Underwriting is distinct
from product development. Thus,
parties must adjust activities associated
with developing structured finance
products or meet the terms of other
available exemptions. Similarly, the
accumulation of securities or other
assets in anticipation of a securitization
or resecuritization is not an activity
conducted ‘‘in connection with’’
underwriting for purposes of the
exemption.412 This activity is typically
engaged in by an issuer or sponsor of a
securitized product in that capacity,
rather than in the capacity of an
underwriter. The underwriting
exemption only permits a banking
entity’s activities when it is acting as an
underwriter.
2. Near Term Customer Demand
Requirement
a. Proposed Near Term Customer
Demand Requirement
Like the statute, § ll.4(a)(2)(v) of the
proposed rule required that the
underwriting activities of the banking
entity with respect to the covered
and these activities do not involve taking positions
that are unrelated to the securities subject to
distribution. See infra IV.A.2.c.2.
410 Although one commenter suggested that an
underwriter’s hedging activity be permitted under
the underwriting exemption, we do not believe the
requirements in the proposed hedging exemption
would be unworkable or overly burdensome in the
context of an underwriter’s hedging activity. See
Goldman (Prop. Trading). As noted above,
underwriting activity is of a relatively distinct
nature, which is substantially different from
market-making activity, which is more dynamic and
involves more frequent trading activity giving rise
to a variety of positions that may naturally hedge
the risks of certain other positions. The Agencies
believe it is appropriate to require that a trading
desk comply with the requirements of the hedging
exemption when it is hedging the risks of its
underwriting position, while allowing a trading
desk’s market making-related hedging under the
market-making exemption.
411 See ICI (Feb. 2012); AFR et al. (Feb. 2012);
Occupy; Alfred Brock.
412 A banking entity may accumulate loans in
anticipation of securitization because loans are not
financial instruments under the final rule. See
supra Part IV.A.1.c.
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financial position be designed not to
exceed the reasonably expected near
term demands of clients, customers, or
counterparties.413
b. Comments Regarding the Proposed
Near Term Customer Demand
Requirement
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Both the statute and the proposed rule
require a banking entity’s underwriting
activity to be ‘‘designed not to exceed
the reasonably expected near term
demands of clients, customers, or
counterparties.’’ 414 Several commenters
requested that this standard be
interpreted in a flexible manner to allow
a banking entity to participate in an
offering that may require it to retain an
unsold allotment for a period of time.415
In addition, one commenter stated that
the final rule should provide flexibility
in this standard by recognizing that the
concept of ‘‘near term’’ differs between
asset classes and depends on the
liquidity of the market.416 Two
commenters expressed views on how
the near term customer demand
requirement should work in the context
of a securitization or creating what the
commenters characterized as
‘‘structured products’’ or ‘‘structured
instruments.’’ 417
Many commenters expressed concern
that the proposed requirement, if
narrowly interpreted, could prevent an
underwriter from holding a residual
position for which there is no
immediate demand from clients,
customers, or counterparties.418
Commenters noted that there are a
variety of offerings that present some
risk of an underwriter having to hold a
residual position that cannot be sold in
the initial distribution, including
413 See proposed rule § ll.4(a)(2)(v); Joint
Proposal, 76 FR 68,867; CFTC Proposal, 77 FR 8353.
414 See supra Part IV.A.2.c.2.a.
415 See SIFMA et al. (Prop. Trading) (Feb. 2012);
BoA; BDA (Feb. 2012); RBC. Another commenter
requested that this requirement be eliminated or
changed to ‘‘underwriting activities of the banking
entity with respect to the covered financial position
must be designed to meet the near-term demands
of clients, customers, or counterparties.’’ See
Japanese Bankers Ass’n.
416 See RBC (stating that the Board has found
acceptable the retention of assets acquired in
connection with underwriting activities for a period
of 90 to 180 days and has further permitted holding
periods of up to a year in certain circumstances,
such as for less liquid securities).
417 See AFR et al. (Feb. 2012); Sens. Merkley &
Levin (Feb. 2012).
418 See SIFMA et al. (Prop. Trading) (Feb. 2012);
BoA; BDA (Feb. 2012); RBC.
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‘‘bought deals,’’ 419 rights offerings,420
and fixed-income offerings.421 A few
commenters noted that similar scenarios
can arise in the case of an AP creating
more shares of an ETF than it can
sell 422 and bridge loans.423 Two
commenters indicated that if the rule
does not provide greater clarity and
flexibility with respect to the near term
customer demand requirement, a
banking entity may be less inclined to
participate in a distribution where there
is the potential risk of an unsold
allotment, may price such risk into the
fees charged to underwriting clients, or
may be forced into a ‘‘fire sale’’ of the
unsold allotment.424
Several other commenters provided
views on whether a banking entity
should be able to hold a residual
position from an offering pursuant to
the underwriting exemption, although
they did not generally link their
comments to the proposed near term
demand requirement.425 Many of these
commenters expressed concern about
permitting a banking entity to retain a
portion of an underwriting and noted
potential risks that may arise from such
419 See SIFMA et al. (Prop. Trading) (Feb. 2012);
BoA; RBC. These commenters generally stated that
an underwriter for a ‘‘bought deal’’ may end up
with an unsold allotment because, pursuant to this
type of offering, an underwriter makes a
commitment to purchase securities from an issuer
or selling security holder, without pre-commitment
marketing to gauge customer interest, in order to
provide greater speed and certainty of execution.
See SIFMA et al. (Prop. Trading) (Feb. 2012); RBC.
420 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(representing that because an underwriter generally
backstops a rights offering by committing to
exercise any rights not exercised by shareholders,
the underwriter may end up holding a residual
portion of the offering if investors do not exercise
all of the rights).
421 See BDA (Feb. 2012). This commenter stated
that underwriters frequently underwrite bonds in
the fixed-income market knowing that they may
need to retain unsold allotments in their inventory.
The commenter indicated that this scenario arises
because the fixed-income market is not as deep as
other markets, so underwriters frequently cannot
sell bonds when they go to market; instead, the
underwriters will retain the bonds until a sufficient
amount of liquidity is available in the market. See
id.
422 See SIFMA et al. (Prop. Trading) (Feb. 2012);
BoA.
423 See BoA; RBC; LSTA (Feb. 2012). One of these
commenters stated that, in the case of securities
issued in lieu of or to refinance bridge loan
facilities, market conditions or investor demand
may change during the period of time between
extension of the bridge commitment and when the
bridge loan is required to be funded or such
securities are required to be issued. As a result, this
commenter requested that the near term demands
of clients, customers, or counterparties be measured
at the time of the initial extension of the bridge
commitment. See LSTA (Feb. 2012).
424 See SIFMA et al. (Prop. Trading) (Feb. 2012);
RBC.
425 See AFR et al. (Feb. 2012); CalPERS; Occupy;
Public Citizen; Goldman (Prop. Trading); Fidelity;
Japanese Bankers Ass’n.; Sens. Merkley & Levin
(Feb. 2012); Alfred Brock.
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5569
activity.426 For example, some of these
commenters stated that retention or
warehousing of underwritten securities
can be an indication of impermissible
proprietary trading intent (particularly if
systematic), or may otherwise result in
high-risk exposures or conflicts of
interests.427 One of these commenters
recommended the Agencies use a metric
to monitor the size of residual positions
retained by an underwriter,428 while
another commenter suggested adding a
requirement to the proposed exemption
to provide that a ‘‘substantial’’ unsold or
retained allotment would be an
indication of prohibited proprietary
trading.429 Similarly, one commenter
recommended that the Agencies
consider whether there are sufficient
provisions in the proposed rule to
reduce the risks posed by banking
entities retaining or warehousing
underwritten instruments, such as
subprime mortgages, collateralized debt
obligation tranches, and high yield debt
of leveraged buyout issuers, which
poses heightened financial risk at the
top of economic cycles.430
Other commenters indicated that
undue restrictions on an underwriter’s
ability to retain a portion of an offering
may result in certain harms to the
capital-raising process. These
commenters represented that unclear or
negative treatment of residual positions
will make banking entities averse to the
risk of an unsold allotment, which may
result in banking entities underwriting
smaller offerings, less capital generation
for issuers, or higher underwriting
discounts, which would increase the
cost of raising capital for businesses.431
One of these commenters suggested that
a banking entity be permitted to hold a
residual position under the
underwriting exemption as long as it
continues to take reasonable steps to
attempt to dispose of the residual
position in light of existing market
conditions.432
In addition, in response to a question
in the proposal, one commenter
426 See AFR et al. (Feb. 2012); CalPERS; Occupy;
Public Citizen; Alfred Brock.
427 See AFR et al. (Feb. 2012) (recognizing,
however, that a small portion of an underwriting
may occasionally be ‘‘hung’’); CalPERS; Occupy
(stating that a banking entity’s retention of unsold
allotments may result in potential conflicts of
interest).
428 See AFR et al. (Feb. 2012).
429 See Occupy (stating that the meaning of the
term ‘‘substantial’’ would depend on the
circumstances of the particular offering).
430 See CalPERS.
431 See Goldman (Prop. Trading); Fidelity
(expressing concern that this may result in a more
concentrated supply of securities and, thus,
decrease the opportunity for diversification in the
portfolios of shareholders’ funds).
432 See Goldman (Prop. Trading).
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expressed the view that the rule should
not require documentation with respect
to residual positions held by an
underwriter.433 In the case of
securitizations, one commenter stated
that if the underwriter wishes to retain
some of the securities or bonds in its
longer-term investment book, such
decisions should be made by a separate
officer, subject to different standards
and compensation.434
Two commenters discussed how the
near term customer demand
requirement should apply in the context
of a banking entity acting as an
underwriter for a securitization or
structured product.435 One of these
commenters indicated that the near term
demand requirement should be
interpreted to require that a distribution
of securities facilitate pre-existing client
demand. This commenter stated that a
banking entity should not be considered
to meet the terms of the proposed
requirement if, on the firm’s own
initiative, it designs and structures a
complex, novel instrument and then
seeks customers for the instrument,
while retaining part of the issuance on
its own book. The commenter further
emphasized that underwriting should
involve two-way demand—clients who
want assistance in marketing their
securities and customers who may wish
to purchase the securities—with the
banking entity serving as an
intermediary.436 Another commenter
indicated that an underwriting should
likely be seen as a distribution of all, or
nearly all, of the securities related to a
securitization (excluding any amount
required for credit risk retention
purposes) along a time line designed not
to exceed reasonably expected near term
demands of clients, customers, or
counterparties. According to the
commenter, this approach would serve
to minimize the arbitrage and risk
concentration possibilities that can arise
through the securitization and sale of
some tranches and the retention of other
tranches.437
One commenter expressed concern
that the proposed near term customer
demand requirement may impact a
banking entity’s ability to act as primary
dealer because some primary dealers are
obligated to bid on each issuance of a
government’s sovereign debt, without
regard to expected customer demand.438
Two other commenters expressed
433 See
Japanese Bankers Ass’n.
Sens. Merkley & Levin (Feb. 2012).
435 See AFR et al. (Feb. 2012); Sens. Merkley &
Levin (Feb. 2012).
436 See AFR et al. (Feb. 2012)
437 See Sens. Merkley & Levin (Feb. 2012).
438 See Banco de Mexico.
´
434 See
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general concern that the proposed
underwriting exemption may be too
narrow to permit banking entities that
act as primary dealers in or for foreign
jurisdictions to continue to meet the
relevant jurisdiction’s primary dealer
requirements.439
c. Final Near Term Customer Demand
Requirement
The final rule requires that the
amount and types of the securities in
the trading desk’s underwriting position
be designed not to exceed the
reasonably expected near term demands
of clients, customers, or counterparties,
and reasonable efforts be made to sell or
otherwise reduce the underwriting
position within a reasonable period,
taking into account the liquidity,
maturity, and depth of the market for
the relevant type of security.440 As
noted above, the near term demand
standard originates from section
13(d)(1)(B) of the BHC Act, and a similar
requirement was included in the
proposed rule.441 The Agencies are
making certain modifications to the
proposed approach in response to
comments.
In particular, the Agencies are
clarifying the operation of this
requirement, particularly with respect to
unsold allotments.442 Under this
requirement, a trading desk must have
a reasonable expectation of demand
from other market participants for the
amount and type of securities to be
acquired from an issuer or selling
security holder for distribution.443 Such
439 See SIFMA et al. (Prop. Trading) (Feb. 2012);
IIB/EBF. One of these commenters represented that
many banking entities serve as primary dealers in
jurisdictions in which they operate, and primary
dealers often: (i) Are subject to minimum purchase
and other obligations in the jurisdiction’s foreign
sovereign debt; (ii) play important roles in
underwriting and market making in State,
provincial, and municipal debt issuances; and (iii)
act as intermediaries through which a government’s
financial and monetary policies operate. This
commenter stated that, due to these considerations,
restrictions on the ability of banking entities to act
as primary dealer are likely to harm the
governments they serve. See IIB/EBF.
440 Final rule § ll.4(a)(2)(ii).
441 The proposed rule required the underwriting
activities of the banking entity with respect to the
covered financial position to be designed not to
exceed the reasonably expected near term demands
of clients, customers, or counterparties. See
proposed rule § ll.4(a)(2)(v).
442 See supra Part IV.A.2.c.2.b. (discussing
commenters’ concerns that the proposed near term
customer demand requirement may limit a banking
entity’s ability to retain an unsold allotment).
443 A banking entity may not structure a complex
instrument on its own initiative using the
underwriting exemption. It may use the
underwriting exemption only with respect to
distributions of securities that comply with the final
rule. The Agencies believe this requirement
addresses one commenter’s concern that a banking
entity could rely on the underwriting exemption
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reasonable expectation may be based on
factors such as current market
conditions and prior experience with
similar offerings of securities. A banking
entity is not required to engage in bookbuilding or similar marketing efforts to
determine investor demand for the
securities pursuant to this requirement,
although such efforts may form the basis
for the trading desk’s reasonable
expectation of demand. While an issuer
or selling security holder can be
considered to be a client, customer, or
counterparty of a banking entity acting
as an underwriter for its distribution of
securities, this requirement cannot be
met by accounting solely for the issuer’s
or selling security holder’s desire to sell
the securities.444 However, the
expectation of demand does not require
a belief that the securities will be placed
immediately. The time it takes to carry
out a distribution may differ based on
the liquidity, maturity, and depth of the
market for the type of security.445
without regard to anticipated customer demand.
See AFR et al. (Feb. 2012) In addition, a trading
desk hedging the risks of an underwriting position
in a complex, novel instrument must comply with
the hedging exemption in the final rule.
444 An issuer or selling security holder for
purposes of this rule may include, among others,
corporate issuers, sovereign issuers for which the
banking entity acts as primary dealer (or functional
equivalent), or any other person that is an issuer,
as defined in final rule § ll.3(e)(9), or a selling
security holder, as defined in final rule § ll
.4(a)(5). The Agencies believe that the underwriting
exemption in the final rule should generally allow
a primary dealer (or functional equivalent) to act as
an underwriter for a sovereign government’s
issuance of its debt because, similar to other
underwriting activities, this involves a banking
entity agreeing to distribute securities for an issuer
(in this case, the foreign sovereign) and engaging in
a distribution of such securities. See SIFMA et al.
(Prop. Trading) (Feb. 2012); IIB/EBF; Banco de
´
Mexico. A banking entity acting as primary dealer
(or functional equivalent) may also be able to rely
on the market-making exemption or other
exemptions for some of its activities. See infra Part
IV.A.3.c.2.c. The final rule defines ‘‘client,
customer, or counterparty’’ for purposes of the
underwriting exemption as ‘‘market participants
that may transact with the banking entity in
connection with a particular distribution for which
the banking entity is acting as underwriter.’’ Final
rule § ll.4(a)(7).
445 One commenter stated that, in the case of a
securitization, an underwriting should be seen as a
distribution of all, or nearly all, of the securities
related to a securitization (excluding the amount
required for credit risk retention purposes) along a
time line designed not to exceed the reasonably
expected near term demands of clients, customers,
or counterparties. See Sens. Merkley & Levin (Feb.
2012). The final rule’s near term customer demand
requirement considers the liquidity, maturity, and
depth of the market for the type of security and
recognizes that the amount of time a trading desk
may need to hold an underwriting position may
vary based on these factors. The final rule does not,
however, adopt a standard that applies differently
based solely on the particular type of security being
distributed (e.g., an asset-backed security versus an
equity security) or that precludes certain types of
securities from being distributed by a banking entity
acting as an underwriter in accordance with the
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This requirement is not intended to
prevent a trading desk from distributing
an offering over a reasonable time
consistent with market conditions or
from retaining an unsold allotment of
the securities acquired from an issuer or
selling security holder where holding
such securities is necessary due to
circumstances such as less-thanexpected purchaser demand at a given
price.446 An unsold allotment is,
however, subject to the requirement to
make reasonable efforts to sell or
otherwise reduce the underwriting
position.447 The definition of
requirements of this exemption because the
Agencies believe the statute is best read to permit
a banking entity to engage in underwriting activity
to facilitate distributions of securities by issuers and
selling security holders, regardless of type, to
provide client-oriented financial services. That
reading is consistent with the statute’s language and
finds support in the legislative history. See 156
Cong. Rec. S5895–S5896 (daily ed. July 15, 2010)
(statement of Sen. Merkley) (stating that the
underwriting exemption permits ‘‘transactions that
are technically trading for the account of the firm
but, in fact, facilitate the provision of near-term
client-oriented financial services’’). In addition,
with respect to this commenter’s statement
regarding credit risk retention requirements, the
Agencies note that compliance with the credit risk
retention requirements of Section 15G of the
Exchange Act would not impact the availability of
the underwriting exemption in the final rule.
446 This approach should help address
commenters’ concerns that an inflexible
interpretation of the near term demand requirement
could result in fire sales, higher fees for
underwriting services, or reluctance to act as an
underwriter for certain types of distributions that
present a greater risk of unsold allotments. See
SIFMA et al. (Prop. Trading) (Feb. 2012); RBC.
Further, the Agencies believe this should reduce
commenters’ concerns that, to the extent a delayed
distribution of securities, which are acquired as a
result of an outstanding bridge loan, is able to
qualify for the underwriting exemption, a stringent
interpretation of the near term demand requirement
could prevent a banking entity from retaining such
securities if market conditions are suboptimal or
marketing efforts are not entirely successful. See
RBC; BoA; LSTA (Feb. 2012). In response to one
commenter’s request that the Agencies allow a
banking entity to assess near term demand at the
time of the initial extension of the bridge
commitment, the Agencies believe it could be
appropriate to determine whether the banking
entity has a reasonable expectation of demand from
other market participants for the amount and type
of securities to be acquired at that time, but note
that the trading desk would continue to be subject
to the requirement to make reasonable efforts to sell
the resulting underwriting position at the time of
the initial distribution and for the remaining time
the securities are in its inventory. See LSTA (Feb.
2012).
447 The Agencies believe that requiring a trading
desk to make reasonable efforts to sell or otherwise
reduce its underwriting position addresses
commenters’ concerns about the risks associated
with unsold allotments or the retention of
underwritten instruments because this requirement
is designed to prevent a trading desk from retaining
an unsold allotment for speculative purposes when
there is customer buying interest for the relevant
security at commercially reasonable prices. Thus,
the Agencies believe this obviates the need for
certain additional requirements suggested by
commenters. See, e.g., Occupy; AFR et al. (Feb.
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‘‘underwriting position’’ includes,
among other things, any residual
position from the distribution that is
managed by the trading desk. The final
rule includes the requirement to make
reasonable efforts to sell or otherwise
reduce the trading desk’s underwriting
position in order to respond to
comments on the issue of when a
banking entity may retain an unsold
allotment when it is acting as an
underwriter, as discussed in more detail
below, and ensure that the exemption is
available only for activities that involve
underwriting activities, and not
prohibited proprietary trading.448
As a general matter, commenters
expressed differing views on whether an
underwriter should be permitted to hold
an unsold allotment for a certain period
of time after the initial distribution. For
example, a few commenters suggested
that limitations on retaining an unsold
allotment would increase the cost of
raising capital 449 or would negatively
impact certain types of securities
offerings (e.g., bought deals, rights
offerings, and fixed-income
offerings).450 Other commenters,
however, expressed concern that the
2012); CalPERS. The final rule strikes an
appropriate balance between the concerns raised by
these commenters and those noted by other
commenters regarding the potential market impacts
of strict requirements against holding an unsold
allotment, such as higher fees to underwriting
clients, fire sales of unsold allotments, or general
reluctance to participate in any distribution that
presents a risk of an unsold allotment. The
requirement to make reasonable efforts to sell or
otherwise reduce the underwriting position should
not cause the market impacts predicted by these
commenters because it does not prevent an
underwriter from retaining an unsold allotment for
a reasonable period or impose strict holding period
limits on unsold allotments. See SIFMA et al. (Prop.
Trading) (Feb. 2012); RBC; Goldman (Prop.
Trading); Fidelity.
448 This approach is generally consistent with one
commenter’s suggested approach to addressing the
issue of unsold allotments. See, e.g., Goldman
(Prop. Trading) (suggesting that a banking entity be
permitted to hold a residual position under the
underwriting exemption as long as it continues to
take reasonable steps to attempt to dispose of the
residual position in light of existing market
conditions). In addition, allowing an underwriter to
retain an unsold allotment under certain
circumstances is consistent with the proposal. See
Joint Proposal, 76 FR 68,867 (‘‘There may be
circumstances in which an underwriter would hold
securities that it could not sell in the distribution
for investment purposes. If the acquisition of such
unsold securities were in connection with the
underwriting pursuant to the permitted
underwriting activities exemption, the underwriter
would also be able to dispose of such securities at
a later time.’’); CFTC Proposal, 77 FR 8352. A
number of commenters raised questions about
whether the rule would permit retaining an unsold
allotment. See Goldman (Prop. Trading); Fidelity;
SIFMA et al. (Prop. Trading) (Feb. 2012); BoA; RBC;
AFR et al. (Feb. 2012); CalPERS; Occupy; Public
Citizen; Alfred Brock.
449 See Goldman (Prop. Trading); Fidelity.
450 See SIFMA et al. (Prop. Trading) (Feb. 2012);
BoA; RBC.
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5571
proposed exemption would allow a
banking entity to retain a portion of a
distribution for speculative purposes.451
The Agencies believe the requirement
to make reasonable efforts to sell or
otherwise reduce the underwriting
position appropriately addresses both
sets of comments. More specifically, this
standard clarifies that an underwriter
generally may retain an unsold
allotment that it was unable to sell to
purchasers as part of the initial
distribution of securities, provided it
had a reasonable expectation of buying
interest and engaged in reasonable
selling efforts.452 This should reduce the
potential for the negative impacts of a
more stringent approach predicted by
commenters, such as increased fees for
underwriting, greater costs to businesses
for raising capital, and potential fire
sales of unsold allotments.453 However,
to address concerns that a banking
entity may retain an unsold allotment
for purely speculative purposes, the
Agencies are requiring that reasonable
efforts be made to sell or otherwise
reduce the underwriting position, which
includes any unsold allotment, within a
reasonable period. The Agencies agree
with these commenters that systematic
retention of an underwriting position,
without engaging in efforts to sell the
position and without regard to whether
the trading desk is able to sell the
securities at a commercially reasonable
price, would be indicative of
impermissible proprietary trading
intent.454 The Agencies recognize that
the meaning of ‘‘reasonable period’’ may
differ based on the liquidity, maturity,
and depth of the market for the relevant
type of securities. For example, an
underwriter may be more likely to retain
an unsold allotment in a bond offering
because liquidity in the fixed-income
market is generally not as deep as that
in the equity market. If a trading desk
retains an underwriting position for a
period of time after the distribution, the
trading desk must manage the risk of its
underwriting position in accordance
with its inventory and risk limits and
authorization procedures. As discussed
above, hedging transactions undertaken
in connection with such risk
management activities must be
conducted in compliance with the
451 See AFR et al. (Feb. 2012); CalPERS; Occupy;
Public Citizen; Alfred Brock.
452 To the extent that an AP for an ETF is able
to meet the terms of the underwriting exemption for
its activity, it may be able to retain ETF shares that
it created if it had a reasonable expectation of
buying interest in the ETF shares and engages in
reasonable efforts to sell the ETF shares. See SIFMA
et al. (Prop. Trading) (Feb. 2012); BoA.
453 See Goldman (Prop. Trading); Fidelity; SIFMA
et al. (Prop. Trading) (Feb. 2012); RBC.
454 See AFR et al. (Feb. 2012); CalPERS; Occupy.
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hedging exemption in § ll.5 of the
final rule.
The Agencies emphasize that the
requirement to make reasonable efforts
to sell or otherwise reduce the
underwriting position applies to the
entirety of the trading desk’s
underwriting position. As a result, this
requirement applies to a number of
different scenarios in which an
underwriter may hold a long or short
position in the securities that are the
subject of a distribution for a period of
time. For example, if an underwriter is
facilitating a distribution of securities
for which there is sufficient investor
demand to purchase the securities at the
offering price, this requirement would
prevent the underwriter from retaining
a portion of the allotment for its own
account instead of selling the securities
to interested investors. If instead there
was insufficient investor demand at the
time of the initial offering, this
requirement would recognize that it
may be appropriate for the underwriter
to hold an unsold allotment for a
reasonable period of time. Under these
circumstances, the underwriter would
need to make reasonable efforts to sell
the unsold allotment when there is
sufficient market demand for the
securities.455 This requirement would
also apply in situations where the
underwriters sell securities in excess of
the number of securities to which the
underwriting commitment relates,
resulting in a syndicate short position in
the same class of securities that were the
subject of the distribution.456 This
provision of the final exemption would
require reasonable efforts to reduce any
portion of the syndicate short position
attributable to the banking entity that is
acting as an underwriter. Such
reduction could be accomplished if, for
example, the managing underwriter
exercises an overallotment option or
shares are purchased in the secondary
market to cover the short position.
The near term demand requirement,
including the requirement to make
reasonable efforts to reduce the
underwriting position, represents a new
regulatory requirement for banking
entities engaged in underwriting. At the
margins, this requirement could alter
the participation decision for some
banking entities with respect to certain
types of distributions, such as
distributions that are more likely to
result in the banking entity retaining an
underwriting position for a period of
455 The trading desk’s retention and sale of the
unsold allotment must comply with the federal
securities laws and regulations, but is otherwise
permitted under the underwriting exemption.
456 See supra note 403.
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time.457 However, the Agencies
recognize that liquidity, maturity, and
depth of the market vary across types of
securities, and the Agencies expect that
the express recognition of these
differences in the rule should help
mitigate any incentive to exit the
underwriting business for certain types
of securities or types of distributions.
3. Compliance Program Requirement
a. Proposed Compliance Program
Requirement
Section ll.4(a)(2)(i) of the proposed
exemption required a banking entity to
establish an internal compliance
program, as required by § ll.20 of the
proposed rule, that is designed to ensure
the banking entity’s compliance with
the requirements of the underwriting
exemption, including reasonably
designed written policies and
procedures, internal controls, and
independent testing.458 This
requirement was proposed so that any
banking entity relying on the
underwriting exemption would have
reasonably designed written policies
and procedures, internal controls, and
independent testing in place to support
its compliance with the terms of the
exemption.459
b. Comments on the Proposed
Compliance Program Requirement
Commenters did not directly address
the proposed compliance program
requirement in the underwriting
exemption. Comments on the proposed
compliance program requirement of
§ ll.20 of the proposed rule are
discussed in Part IV.C., below.
c. Final Compliance Program
Requirement
The final rule includes a compliance
program requirement that is similar to
the proposed requirement, but the
Agencies are making certain
enhancements to emphasize the
importance of a strong internal
compliance program. More specifically,
the final rule requires that a banking
entity’s compliance program specifically
include reasonably designed written
policies and procedures, internal
457 For example, some commenters suggested that
the proposed underwriting exemption could have a
chilling effect on banking entities’ willingness to
engage in underwriting activities. See, e.g., Lord
Abbett; Fidelity. Further, some commenters
expressed concern that the proposed near term
customer demand requirement might negatively
impact certain forms of capital-raising if the
requirement is interpreted narrowly or inflexibly.
See SIFMA et al. (Prop. Trading) (Feb. 2012); BoA;
BDA (Feb. 2012); RBC.
458 See proposed rule § ll.4(a)(2)(i).
459 See Joint Proposal, 76 FR 68,866; CFTC
Proposal, 77 FR 8352.
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controls, analysis and independent
testing 460 identifying and addressing: (i)
The products, instruments or exposures
each trading desk may purchase, sell, or
manage as part of its underwriting
activities; 461 (ii) limits for each trading
desk, based on the nature and amount
of the trading desk’s underwriting
activities, including the reasonably
expected near term demands of clients,
customers, or counterparties; 462 (iii)
internal controls and ongoing
monitoring and analysis of each trading
desk’s compliance with its limits; 463
and (iv) authorization procedures,
including escalation procedures that
require review and approval of any
trade that would exceed one or more of
a trading desk’s limits, demonstrable
analysis of the basis for any temporary
or permanent increase to one or more of
a trading desk’s limits, and independent
review (i.e., by risk managers and
compliance officers at the appropriate
level independent of the trading desk) of
such demonstrable analysis and
approval.464
As noted above, the proposed
compliance program requirement did
not include the four specific elements
listed above in the proposed
underwriting exemption, although each
of these provisions was included in
some form in the detailed compliance
program requirement under Appendix C
of the proposed rule.465 The Agencies
are moving these particular
requirements, with certain
enhancements, into the underwriting
exemption because the Agencies believe
these are core elements of a program to
ensure compliance with the
underwriting exemption. These
compliance procedures must be
established, implemented, maintained,
and enforced for each trading desk
engaged in underwriting activity under
§ ll.4(a) of the final rule. Each of the
460 The independent testing standard is discussed
in more detail in Part IV.C., which discusses the
compliance program requirement in § ll.20 of the
final rule.
461 See final rule § ll.4(a)(2)(iii)(A).
462 See final rule § ll.4(a)(2)(iii)(B). A trading
desk must have limits on the amount, types, and
risk of the securities in its underwriting position,
level of exposures to relevant risk factors arising
from its underwriting position, and period of time
a security may be held. See id.
463 See final rule § ll.4(a)(2)(iii)(C).
464 See final rule § ll.4(a)(2)(iii)(D).
465 See Joint Proposal, 76 FR 68,963–68,967
(requiring certain banking entities to establish,
maintain, and enforce compliance programs with,
among other things: (i) Written policies and
procedures that describe a trading unit’s authorized
instruments and products; (ii) internal controls for
each trading unit, including risk limits for each
trading unit and surveillance procedures; and (iii)
a management framework, including management
procedures for overseeing compliance with the
proposed rule).
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requirements in paragraphs (a)(2)(iii)(A)
through (D) must be appropriately
tailored to the individual trading
activities and strategies of each trading
desk.
The compliance program requirement
in the underwriting exemption is
substantially similar to the compliance
program requirement in the marketmaking exemption, except that the
Agencies are requiring more detailed
risk management procedures in the
market-making exemption due to the
nature of that activity.466 The Agencies
believe including similar compliance
program requirements in the
underwriting and market-making
exemptions may reduce burdens
associated with building and
maintaining compliance programs for
each trading desk.
Identifying in the compliance
program the relevant products,
instruments, and exposures in which a
trading desk is permitted to trade will
facilitate monitoring and oversight of
compliance with the underwriting
exemption. For example, this
requirement should prevent an
individual trader on an underwriting
desk from establishing positions in
instruments that are unrelated to the
desk’s underwriting function. Further,
the identification of permissible
products, instruments, and exposures
will help form the basis for the specific
types of position and risk limits that the
banking entity must establish and is
relevant to considerations throughout
the exemption regarding the liquidity,
maturity, and depth of the market for
the relevant type of security.
A trading desk must have limits on
the amount, types, and risk of the
securities in its underwriting position,
level of exposures to relevant risk
factors arising from its underwriting
position, and period of time a security
may be held. Limits established under
this provision, and any modifications to
these limits made through the required
escalation procedures, must account for
the nature and amount of the trading
desk’s underwriting activities, including
the reasonably expected near term
demands of clients, customers, or
counterparties. Among other things,
these limits should be designed to
prevent a trading desk from
systematically retaining unsold
allotments even when there is customer
demand for the positions that remain in
the trading desk’s inventory. The
Agencies recognize that trading desks’
limits may differ across types of
securities and acknowledge that trading
466 See final rule §§ ll.4(a)(2)(iii),
ll.4(b)(2)(iii).
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desks engaged in underwriting activities
in less liquid securities, such as
corporate bonds, may require different
inventory, risk exposure, and holding
period limits than trading desks engaged
in underwriting activities in more liquid
securities, such as certain equity
securities. A trading desk hedging the
risks of an underwriting position must
comply with the hedging exemption,
which provides for compliance
procedures regarding risk
management.467
Furthermore, a banking entity must
establish internal controls and ongoing
monitoring and analysis of each trading
desk’s compliance with its limits,
including the frequency, nature, and
extent of a trading desk exceeding its
limits.468 This may include the use of
management and exception reports.
Moreover, the compliance program must
set forth a process for determining the
circumstances under which a trading
desk’s limits may be modified on a
temporary or permanent basis (e.g., due
to market changes).
As noted above, a banking entity’s
compliance program for trading desks
engaged in underwriting activity must
also include escalation procedures that
require review and approval of any
trade that would exceed one or more of
a trading desk’s limits, demonstrable
analysis that the basis for any temporary
or permanent increase to one or more of
a trading desk’s limits is consistent with
the near term customer demand
requirement, and independent review of
such demonstrable analysis and
approval.469 Thus, to increase a limit of
a trading desk, there must be an analysis
of why such increase would be
appropriate based on the reasonably
expected near term demands of clients,
customers, or counterparties, which
must be independently reviewed. A
banking entity also must maintain
documentation and records with respect
to these elements, consistent with the
requirement of § ll.20(b)(6).
As discussed in more detail in Part
IV.C., the Agencies recognize that the
compliance program requirements in
the final rule will impose certain costs
on banking entities but, on balance, the
Agencies believe such requirements are
necessary to facilitate compliance with
the statute and the final rule and to
reduce the risk of evasion.470
final rule § ll.5.
final rule § ll.4(a)(2)(iii)(C).
469 See final rule § ll.4(a)(2)(iii)(D).
470 See Part IV.C. (discussing the compliance
program requirement in § ll.20 of the final rule).
467 See
468 See
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4. Compensation Requirement
a. Proposed Compensation Requirement
Another provision of the proposed
underwriting exemption required that
the compensation arrangements of
persons performing underwriting
activities at the banking entity must be
designed not to encourage proprietary
risk-taking.471 In connection with this
requirement, the proposal clarified that
although a banking entity relying on the
underwriting exemption may
appropriately take into account
revenues resulting from movements in
the price of securities that the banking
entity underwrites to the extent that
such revenues reflect the effectiveness
with which personnel have managed
underwriting risk, the banking entity
should provide compensation
incentives that primarily reward client
revenues and effective client service,
not proprietary risk-taking.472
b. Comments on the Proposed
Compensation Requirement
A few commenters expressed general
support for the proposed requirement,
but suggested certain modifications that
they believed would enhance the
requirement and make it more
effective.473 Specifically, one
commenter suggested tailoring the
requirement to underwriting activity by,
for example, ensuring that personnel
involved in underwriting are given
compensation incentives for the
successful distribution of securities off
the firm’s balance sheet and are not
rewarded for profits associated with
securities that are not successfully
distributed (although losses from such
positions should be taken into
consideration in determining the
employee’s compensation). This
commenter further recommended that
bonus compensation for a deal be
withheld until all or a high percentage
of the relevant securities are
distributed.474 Finally, one commenter
suggested that the term ‘‘designed’’
should be removed from this
provision.475
c. Final Compensation Requirement
Similar to the proposed rule, the
underwriting exemption in the final rule
requires that the compensation
arrangements of persons performing the
banking entity’s underwriting activities,
as described in the exemption, be
471 See proposed rule § ll.4(a)(2)(vii); Joint
Proposal, 76 FR 68,868; CFTC Proposal, 77 FR 8353.
472 See id.
473 See Occupy; AFR et al. (Feb. 2012); Better
Markets (Feb. 2012).
474 See AFR et al. (Feb. 2012).
475 See Occupy.
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designed not to reward or incentivize
prohibited proprietary trading.476 The
Agencies do not intend to preclude an
employee of an underwriting desk from
being compensated for successful
underwriting, which involves some risktaking.
Consistent with the proposal,
activities for which a banking entity has
established a compensation incentive
structure that rewards speculation in,
and appreciation of, the market value of
securities underwritten by the banking
entity are inconsistent with the
underwriting exemption. A banking
entity may, however, take into account
revenues resulting from movements in
the price of securities that the banking
entity underwrites to the extent that
such revenues reflect the effectiveness
with which personnel have managed
underwriting risk. The banking entity
should provide compensation
incentives that primarily reward client
revenues and effective client services,
not prohibited proprietary trading. For
example, a compensation plan based
purely on net profit and loss with no
consideration for inventory control or
risk undertaken to achieve those profits
would not be consistent with the
underwriting exemption.
The Agencies are not adopting an
approach that prevents an employee
from receiving any compensation
related to profits arising from an unsold
allotment, as suggested by one
commenter, because the Agencies
believe the final rule already includes
sufficient controls to prevent a trading
desk from intentionally retaining an
unsold allotment to make a speculative
profit when such allotment could be
sold to customers.477 The Agencies also
are not requiring compensation to be
vested for a period of time, as
recommended by one commenter to
reduce traders’ incentives for undue
risk-taking. The Agencies believe the
final rule includes sufficient controls
around risk-taking activity without a
compensation vesting requirement
because a banking entity must establish
limits for a trading desk’s underwriting
position and the trading desk must
make reasonable efforts to sell or
otherwise reduce the underwriting
position within a reasonable period.478
The Agencies continue to believe it is
476 See final rule § ll.4(a)(2)(iv); proposed rule
§ ll.4(a)(2)(vii). This is consistent with the final
compensation requirements in the market-making
and hedging exemptions. See final rule § ll
.4(b)(2)(v); final rule § ll.5(b)(3).
477 See AFR et al. (Feb. 2012); supra Part
IV.A.2.c.2.c. (discussing the requirement to make
reasonable efforts to sell or otherwise reduce the
underwriting position).
478 See AFR et al. (Feb. 2012).
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appropriate to focus on the design of a
banking entity’s compensation
structure, so the Agencies are not
removing the term ‘‘designed’’ from this
provision.479 This retains an objective
focus on actions that the banking entity
can control—the design of its incentive
compensation program—and avoids a
subjective focus on whether an
employee feels incentivized by
compensation, which may be more
difficult to assess. In addition, the
framework of the final compensation
requirement will allow banking entities
to better plan and control the design of
their compensation arrangements,
which should reduce costs and
uncertainty and enhance monitoring,
than an approach focused solely on
individual outcomes.
5. Registration Requirement
a. Proposed Registration Requirement
Section ll.4(a)(2)(iv) of the
proposed rule would have required that
a banking entity have the appropriate
dealer registration or be exempt from
registration or excluded from regulation
as a dealer to the extent that, in order
to underwrite the security at issue, a
person must generally be a registered
securities dealer, municipal securities
dealer, or government securities
dealer.480 Further, if the banking entity
was engaged in the business of a dealer
outside the United States in a manner
for which no U.S. registration is
required, the proposed rule would have
required the banking entity to be subject
to substantive regulation of its dealing
business in the jurisdiction in which the
business is located.
b. Comments on Proposed Registration
Requirement
Commenters generally did not address
the proposed dealer requirement in the
underwriting exemption. However, as
discussed below in Part IV.A.3.c.2.b., a
number of commenters addressed a
similar requirement in the proposed
market-making exemption.
c. Final Registration Requirement
The requirement in § ll.4(a)(2)(vi)
of the underwriting exemption, which
provides that the banking entity must be
licensed or registered to engage in
underwriting activity in accordance
with applicable law, is substantively
479 See
Occupy.
480 See proposed rule § ll.4(a)(2)(iv); Joint
Proposal, 76 FR 68,867; CFTC Proposal, 77 FR 8353.
The proposal clarified that, in the case of a financial
institution that is a government securities dealer,
such institution must have filed notice of that status
as required by section 15C(a)(1)(B) of the Exchange
Act. See Joint Proposal, 76 FR 68,867; CFTC
Proposal, 77 FR 8353.
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similar to the proposed dealer
registration requirement in § ll
.4(a)(2)(iv) of the proposed rule. The
primary difference between the
proposed requirement and the final
requirement is that the Agencies have
simplified the language of the rule. The
Agencies have also made conforming
changes to the corresponding
requirement in the market-making
exemption to promote consistency
across the exemptions, where
appropriate.481
As was proposed, this provision will
require a U.S. banking entity to be an
SEC-registered dealer in order to rely on
the underwriting exemption in
connection with a distribution of
securities—other than exempted
securities, security-based swaps,
commercial paper, bankers acceptances
or commercial bills—unless the banking
entity is exempt from registration or
excluded from regulation as a dealer.482
To the extent that a banking entity relies
on the underwriting exemption in
connection with a distribution of
municipal securities or government
securities, rather than the exemption in
§ ll.6(a) of the final rule, this
provision may require the banking
entity to be registered or licensed as a
municipal securities dealer or
government securities dealer, if required
by applicable law. However, this
provision does not require a banking
entity to register in order to qualify for
the underwriting exemption if the
banking entity is not otherwise required
to register by applicable law.
The Agencies have determined that,
for purposes of the underwriting
exemption, rather than require a
banking entity engaged in the business
of a securities dealer outside the United
States to be subject to substantive
regulation of its dealing business in the
jurisdiction in which the business is
located, a banking entity’s dealing
activity outside the U.S. should only be
subject to licensing or registration
provisions if required under applicable
foreign law (provided no U.S.
registration or licensing requirements
apply to the banking entity’s activities).
In response to comments, the final rule
recognizes that certain foreign
jurisdictions may not provide for
substantive regulation of dealing
481 See Part IV.A.3.c.6. (discussing the registration
requirement in the market-making exemption).
482 For example, if a banking entity is a bank
engaged in underwriting asset-backed securities for
which it would be required to register as a
securities dealer but for the exclusion contained in
section 3(a)(5)(C)(iii) of the Exchange Act, the final
rule would not require the banking entity to be a
registered securities dealer to underwrite the assetbacked securities. See 15 U.S.C. 78c(a)(5)(C)(iii).
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businesses.483 The Agencies do not
believe it is necessary to preclude
banking entities from engaging in
underwriting activities in such foreign
jurisdictions to achieve the goals of
section 13 of the BHC Act because these
banking entities would continue to be
subject to the other requirements of the
underwriting exemption.
6. Source of Revenue Requirement
a. Proposed Source of Revenue
Requirement
Under § ll.4(a)(2)(vi) of the
proposed rule, the underwriting
activities of a banking entity would have
been required to be designed to generate
revenues primarily from fees,
commissions, underwriting spreads, or
other income not attributable to
appreciation in the value of covered
financial positions or hedging of
covered financial positions.484 The
proposal clarified that underwriting
spreads would include any ‘‘gross
spread’’ (i.e., the difference between the
price an underwriter sells securities to
the public and the price it purchases
them from the issuer) designed to
compensate the underwriter for its
services.485 This requirement provided
that activities conducted in reliance on
the underwriting exemption should
demonstrate patterns of revenue
generation and profitability consistent
with, and related to, the services an
underwriter provides to its customers in
bringing securities to market, rather
than changes in the market value of the
underwritten securities.486
b. Comments on the Proposed Source of
Revenue Requirement
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A few commenters requested certain
modifications to the proposed source of
revenue requirement. These
commenters’ suggested revisions were
generally intended either to refine the
standard to better account for certain
activities or to make it more
stringent.487 Three commenters
expressed concern that the proposed
source of revenue requirement would
negatively impact a banking entity’s
483 See infra Part IV.A.3.c.6.c. (discussing
comments on this issue with respect to the
proposed dealer registration requirement in the
market-making exemption).
484 See proposed rule § ll.4(a)(2)(vi); Joint
Proposal, 76 FR 68,867–68,868; CFTC Proposal, 77
FR 8353.
485 See Joint Proposal, 76 FR 68,867–68,868
n.142; CFTC Proposal, 77 FR 8353 n.148.
486 See Joint Proposal, 76 FR 68,867–68,868;
CFTC Proposal, 77 FR 8353.
487 See Goldman (Prop. Trading); Occupy; Sens.
Merkley & Levin (Feb. 2012).
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ability to act as a primary dealer or in
a similar capacity.488
With respect to suggested
modifications, one commenter
recommended that ‘‘customer revenue’’
include revenues attributable to
syndicate activities, hedging activities,
and profits and losses from sales of
residual positions, as long as the
underwriter makes a reasonable effort to
dispose of any residual position in light
of existing market conditions.489
Another commenter indicated that the
rule would better address securitization
if it required compensation to be linked
in part to risk minimization for the
securitizer and in part to serving
customers. This commenter suggested
that such a framework would be
preferable because, in the context of
securitizations, fee-based compensation
structures did not previously prevent
banking entities from accumulating
large and risky positions with
significant market exposure.490
To strengthen the proposed
requirement, one commenter requested
that the terms ‘‘designed’’ and
‘‘primarily’’ be removed and replaced by
the word ‘‘solely.’’ 491 Two other
commenters requested that this
requirement be interpreted to prevent a
banking entity from acting as an
underwriter for a distribution of
securities if such securities lack a
discernible and sufficiently liquid preexisting market and a foreseeable market
price.492
c. Final Rule’s Approach To Assessing
Source of Revenue
The Agencies believe the final rule
includes sufficient controls around an
underwriter’s source of revenue and
have determined not to adopt the
additional requirement included in
proposed rule § ll.4(a)(2)(vi). The
Agencies believe that removing this
requirement addresses commenters’
concerns that the proposed requirement
488 See Banco de Mexico (stating that primary
´
dealers need to profit from resulting proprietary
positions in foreign sovereign debt, including by
holding significant positions in anticipation of
future price movements, in order to make the
primary dealer business financially attractive); IIB/
EBF (noting that primary dealers may actively seek
to profit from price and interest rate movements of
their holdings, which the relevant sovereign entity
supports because such activity provides muchneeded liquidity for securities that are otherwise
largely purchased pursuant to buy-and-hold
strategies by institutional investors and other
entities seeking safe returns and liquidity buffers);
Japanese Bankers Ass’n.
489 See Goldman (Prop. Trading).
490 See Sens. Merkley & Levin (Feb. 2012).
491 See Occupy (requesting that the rule require
automatic disgorgement of any profits arising from
appreciation in the value of positions in connection
with underwriting activities).
492 See AFR et al. (Feb. 2012); Public Citizen.
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5575
did not appropriately reflect certain
revenue sources from underwriting
activity 493 or may impact primary
dealer activities.494 At the same time,
the final rule continues to include
provisions that focus on whether an
underwriter is generating underwritingrelated revenue and that should limit an
underwriter’s ability to generate
revenues purely from price
appreciation. In particular, the
requirement to make reasonable efforts
to sell or otherwise reduce the
underwriting position within a
reasonable period, which was not
included in the proposed rule, should
limit an underwriter’s ability to gain
revenues purely from price appreciation
related to its underwriter position.
Similarly, the determination of whether
an underwriter receives special
compensation for purposes of the
definition of ‘‘distribution’’ takes into
account whether a banking entity is
generating underwriting-related
revenue.
The final rule does not adopt a
requirement that prevents an
underwriter from generating any
revenue from price appreciation out of
concern that such a requirement could
prevent an underwriter from retaining
an unsold allotment under any
circumstances, which would be
inconsistent with other provisions of the
exemption.495 Similarly, the Agencies
are not adopting a source of revenue
requirement that would prevent a
banking entity from acting as
underwriter for a distribution of
securities if such securities lack a
discernible and sufficiently liquid preexisting market and a foreseeable market
price, as suggested by two
commenters.496 The Agencies believe
these commenters’ concern is mitigated
by the near term demand requirement,
which requires a trading desk to have a
reasonable expectation of demand from
other market participants for the amount
and type of securities to be acquired
from an issuer or selling security holder
for distribution.497 Further, one
commenter recommended a revenue
requirement directed at securitization
activities to prevent banking entities
from accumulating large and risky
positions with significant market
493 See
Goldman (Prop. Trading).
´
Banco de Mexico; IIB/EBF; Japanese
Bankers Ass’n.
495 See Occupy; supra Part IV.A.2.c.2. (discussing
comments on unsold allotments and the
requirement in the final rule to make reasonable
efforts to sell or otherwise reduce the underwriting
position).
496 See AFR et al. (Feb. 2012); Public Citizen.
497 See supra Part IV.A.2.c.2.
494 See
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exposure.498 The Agencies believe the
requirement to make reasonable efforts
to sell or otherwise reduce the
underwriting position should achieve
this stated goal and, thus, the Agencies
do not believe an additional revenue
requirement for securitization activity is
needed.499
3. Section ll.4(b): Market-Making
Exemption
a. Introduction
In adopting the final rule, the
Agencies are striving to balance two
goals of section 13 of the BHC Act: To
allow market making, which is
important to well-functioning markets
as well as to the economy, and
simultaneously to prohibit proprietary
trading, unrelated to market making or
other permitted activities, that poses
significant risks to banking entities and
the financial system. In response to
comments on the proposed marketmaking exemption, the Agencies are
adopting certain modifications to the
proposed exemption to better account
for the varying characteristics of market
making-related activities across markets
and asset classes, while requiring that
banking entities maintain a robust set of
risk controls for their market makingrelated activities. A flexible approach to
this exemption is appropriate because
the activities a market maker undertakes
to provide important intermediation and
liquidity services will differ based on
the liquidity, maturity, and depth of the
market for a given type of financial
instrument. The statute specifically
permits banking entities to continue to
provide these beneficial services to their
clients, customers, and
counterparties.500 Thus, the Agencies
are adopting an approach that
recognizes the full scope of market
making-related activities banking
entities currently undertake and
requires that these activities be subject
to clearly defined, verifiable, and
monitored risk parameters.
b. Overview
1. Proposed Market-Making Exemption
Section 13(d)(1)(B) of the BHC Act
provides an exemption from the
498 See
Sens. Merkley & Levin (Feb. 2012).
final rule § ll.4(a)(2)(ii). Further, as
noted above, this exemption does not permit the
accumulation of assets for securitization. See supra
Part IV.A.2.c.1.c.v.
500 As discussed in Part IV.A.3.c.2.c.i., infra, the
terms ‘‘client,’’ ‘‘customer,’’ and ‘‘counterparty’’ are
defined in the same manner in the final rule. Thus,
the Agencies use these terms synonymously
throughout this discussion and sometimes use the
term ‘‘customer’’ to refer to all entities that meet the
definition of ‘‘client, customer, and counterparty’’
in the final rule’s market-making exemption.
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499 See
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prohibition on proprietary trading for
the purchase, sale, acquisition, or
disposition of securities, derivatives,
contracts of sale of a commodity for
future delivery, and options on any of
the foregoing in connection with market
making-related activities, to the extent
that such activities are designed not to
exceed the reasonably expected near
term demands of clients, customers, or
counterparties.501
Section ll.4(b) of the proposed rule
would have implemented this statutory
exemption by requiring that a banking
entity’s market making-related activities
comply with seven standards. As
discussed in the proposal, these
standards were designed to ensure that
any banking entity relying on the
exemption would be engaged in bona
fide market making-related activities
and, further, would conduct such
activities in a way that was not
susceptible to abuse through the taking
of speculative, proprietary positions as
a part of, or mischaracterized as, market
making-related activities. The Agencies
proposed to use additional regulatory
and supervisory tools in conjunction
with the proposed market-making
exemption, including quantitative
measurements for banking entities
engaged in significant covered trading
activity in proposed Appendix A,
commentary on how the Agencies
proposed to distinguish between
permitted market making-related
activity and prohibited proprietary
trading in proposed Appendix B, and a
compliance regime in proposed § ll
.20 and, where applicable, Appendix C
of the proposal. This multi-faceted
approach was intended to address the
complexities of differentiating permitted
market making-related activities from
prohibited proprietary trading.502
2. Comments on the Proposed MarketMaking Exemption
The Agencies received significant
comment regarding the proposed
market-making exemption. In this Part,
the Agencies highlight the main issues,
concerns, and suggestions raised by
commenters with respect to the
proposed market-making exemption. As
discussed in greater detail below,
commenters’ views on the effectiveness
of the proposed exemption varied.
Commenters discussed a broad range of
topics related to the proposed marketmaking exemption including, among
others: The overall scope of the
proposed exemption and potential
restrictions on market making in certain
501 12
U.S.C. 1851(d)(1)(B).
Joint Proposal, 76 FR 68,869; CFTC
Proposal, 77 FR 8354–8355.
502 See
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markets or asset classes; the potential
market impact of the proposed marketmaking exemption; the appropriate level
of analysis for compliance with the
proposed exemption; the effectiveness
of the individual requirements of the
proposed exemption; and specific
activities that should or should not be
considered permitted market makingrelated activity under the rule.
a. Comments on the Overall Scope of
the Proposed Exemption
With respect to the general scope of
the exemption, a number of commenters
expressed concern that the proposed
approach to implementing the marketmaking exemption is too narrow or
restrictive, particularly with respect to
less liquid markets. These commenters
expressed concern that the proposed
exemption would not be workable in
many markets and asset classes and
does not take into account how marketmaking services are provided in those
markets and asset classes.503 Some
commenters expressed particular
concern that the proposed exemption
may restrict or limit certain activities
currently conducted by market makers
(e.g., holding inventory or interdealer
trading).504 Several commenters stated
503 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (stating that the proposed exemption ‘‘seems
to view market making based on a liquid, exchangetraded equity model in which market makers are
simple intermediaries akin to agents’’ and that
‘‘[t]his view does not fit market making even in
equity markets and widely misses the mark for the
vast majority of markets and asset classes’’); SIFMA
(Asset Mgmt.) (Feb. 2012); Credit Suisse (Seidel);
ICI (Feb. 2012); BoA; Columbia Mgmt.; Comm. on
Capital Markets Regulation; Invesco; ASF (Feb.
2012) (‘‘The seven criteria in the proposed rule, and
the related criterion for identifying permitted
hedging, are overly restrictive and will make it
impractical for dealers to continue making markets
in most securitized products.’’); Chamber (Feb.
2012) (expressing particular concern about the
commercial paper market).
504 Several commenters stated that the proposed
rule would limit a market maker’s ability to
maintain inventory. See, e.g., NASP; Oliver Wyman
(Dec. 2011); Wellington; Prof. Duffie; Standish
Mellon; MetLife; Lord Abbett; NYSE Euronext;
CIEBA; British Columbia; SIFMA et al. (Prop.
Trading) (Feb. 2012); Shadow Fin. Regulatory
Comm.; Credit Suisse (Seidel); Morgan Stanley;
Goldman (Prop. Trading); BoA; STANY; SIFMA
(Asset Mgmt.) (Feb. 2012); Chamber (Feb. 2012);
IRSG; Abbott Labs et al. (Feb. 14, 2012); Abbott Labs
et al. (Feb. 21, 2012); Australian Bankers Ass’n.
(Feb. 2012); FEI; ASF (Feb. 2012); RBC; PUC Texas;
Columbia Mgmt.; SSgA (Feb. 2012); PNC et al.;
Fidelity; ICI (Feb. 2012); British Bankers’ Ass’n.;
Comm. on Capital Markets Regulation; IHS; Oliver
Wyman (Feb. 2012); Thakor Study (stating that by
artificially constraining the security holdings that a
banking entity can have in its inventory for market
making or proprietary trading purposes, section 13
of the BHC Act will make bank risk management
less efficient and may adversely impact the
diversified financial services business model of
banks). However, some commenters stated that
market makers should seek to minimize their
inventory or should not need large inventories. See,
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that the proposed exemption would
create too much uncertainty regarding
compliance 505 and, further, may have a
chilling effect on banking entities’
market making-related activities.506 Due
to the perceived restrictions and
burdens of the proposed exemption,
many commenters indicated that the
rule may change the way in which
market-making services are provided.507
A number of commenters expressed the
view that the proposed exemption is
inconsistent with Congressional intent
because it would restrict and reduce
banking entities’ current market makingrelated activities.508
Other commenters, however, stated
that the proposed exemption was too
broad and recommended that the rule
place greater restrictions on market
making, particularly in illiquid,
nontransparent markets.509 Many of
these commenters suggested that the
exemption should only be available for
traditional market-making activity in
relatively safe, ‘‘plain vanilla’’
e.g., AFR et al. (Feb. 2012); Public Citizen; Johnson
& Prof. Stiglitz. Other commenters expressed
concern that the proposed rule could limit
interdealer trading. See, e.g., Prof. Duffie; Credit
Suisse (Seidel); JPMC; Morgan Stanley; Goldman
(Prop. Trading); Chamber (Feb. 2012); Oliver
Wyman (Dec. 2011).
505 See, e.g., BlackRock; Putnam; Fixed Income
Forum/Credit Roundtable; ACLI (Feb. 2012);
MetLife; IAA; Wells Fargo (Prop. Trading); T. Rowe
Price; Sen. Bennet; Sen. Corker; PUC Texas;
Fidelity; ICI (Feb. 2012); Invesco.
506 See, e.g., Wellington; Prof. Duffie; Standish
Mellon; Commissioner Barnier; NYSE Euronext;
BoA; Citigroup (Feb. 2012); STANY; ICE; Chamber
(Feb. 2012); BDA (Feb. 2012); Putnam; FTN; Fixed
Income Forum/Credit Roundtable; ACLI (Feb.
2012); IAA; CME Group; Capital Group; PUC Texas;
Columbia Mgmt.; SSgA (Feb. 2012); Eaton Vance;
ICI (Feb. 2012); Invesco; Comm. on Capital Markets
Regulation; Oliver Wyman (Feb. 2012); SIFMA
(Asset Mgmt.) (Feb. 2012); Thakor Study.
507 For example, some commenters stated that
market makers may revert to an agency or ‘‘special
order’’ model. See, e.g., Barclays; Goldman (Prop.
Trading); ACLI (Feb. 2012); Vanguard; RBC. In
addition, some commenters stated that new systems
will be developed, such as alternative market
matching networks, but these commenters
disagreed about whether such changes would
happen in the near term. See, e.g., CalPERS;
BlackRock; Stuyvesant; Comm. on Capital Markets
Regulation. Other commenters stated that it is
unlikely that new systems will be developed. See,
e.g., SIFMA et al. (Prop. Trading) (Feb. 2012); Oliver
Wyman (Feb. 2012). One commenter stated that the
proposed rule may cause a banking organization
that engages in significant market-making activity to
give up its banking charter or spin off its marketmaking operations to avoid compliance with the
proposed exemption. See Prof. Duffie.
508 See, e.g., NASP; Wellington; JPMC; Morgan
Stanley; Credit Suisse (Seidel); BoA; Goldman
(Prop. Trading); Citigroup (Feb. 2012); STANY;
SIFMA (Asset Mgmt.) (Feb. 2012); Chamber (Feb.
2012); Putnam; ICI (Feb. 2012); Wells Fargo (Prop.
Trading); NYSE Euronext; Sen. Corker; Invesco.
509 See, e.g., Better Markets (Feb. 2012); Sens.
Merkley & Levin (Feb. 2012); Occupy; AFR et al.
(Feb. 2012); Public Citizen; Johnson & Prof. Stiglitz.
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instruments.510 Two commenters
represented that the proposed
exemption would have little to no
impact on banking entities’ current
market making-related services.511
Commenters expressed differing
views regarding the ease or difficulty of
distinguishing permitted market
making-related activity from prohibited
proprietary trading. A number of
commenters represented that it is
difficult or impossible to distinguish
prohibited proprietary trading from
permitted market making-related
activity.512 With regard to this issue,
several commenters recommended that
the Agencies not try to remove all
aspects of proprietary trading from
market making-related activity because
doing so would likely restrict certain
legitimate market-making activity.513
Other commenters were of the view
that it is possible to differentiate
between prohibited proprietary trading
and permitted market making-related
activity.514 For example, one commenter
stated that, while the analysis may
involve subtle distinctions, the
fundamental difference between a
banking entity’s market-making
activities and proprietary trading
activities is the emphasis in market
making on seeking to meet customer
needs on a consistent and reliable basis
throughout a market cycle.515 According
to another commenter, holding
substantial securities in a trading book
for an extended period of time assumes
the character of a proprietary position
and, while there may be occasions when
510 See, e.g., Johnson & Prof. Stiglitz; Sens.
Merkley & Levin (Feb. 2012); Occupy; AFR et al.
(Feb. 2012); Public Citizen.
511 See Occupy (‘‘[I]t is unclear that this rule, as
written, will markedly alter the current customerserving business. Indeed, this rule has gone to
excessive lengths to protect the covered banking
entities’ ability to maintain responsible customerfacing business.’’); Alfred Brock.
512 See, e.g., Rep. Bachus et al.; IIF; Morgan
Stanley (stating that beyond walled-off proprietary
trading, the line is hard to draw, particularly
because both require principal risk-taking and the
features of market making vary across markets and
asset classes and become more pronounced in times
of market stress); CFA Inst. (representing that the
distinction is particularly difficult in the fixedincome market); ICFR; Prof. Duffie; WR Hambrecht.
513 See, e.g., Chamber (Feb. 2012) (citing an article
by Stephen Breyer stating that society should not
expend disproportionate resources trying to reduce
or eliminate ‘‘the last 10 percent’’ of the risks of a
certain problem); JPMC; RBC; ICFR; Sen. Hagan.
One of these commenters indicated that any
concerns that banking entities would engage in
speculative trading as a result of an expansive
market-making exemption would be addressed by
other reform initiatives (e.g., Basel III
implementation will provide laddered disincentives
to holding positions as principal as a result of
capital and liquidity requirements). See RBC.
514 See Wellington; Paul Volcker; Better Markets
(Feb. 2012); Occupy.
515 See Wellington.
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5577
a customer-oriented purchase and
subsequent sale extend over days and
cannot be more quickly executed or
hedged, substantial holdings of this
character should be relatively rare and
limited to less liquid markets.516
Several commenters expressed
general concern that the proposed
exemption may be applied on a
transaction-by-transaction basis and
explained the burdens that may result
from such an approach.517 Commenters
appeared to attribute these concerns to
language in the proposed exemption
referring to a ‘‘purchase or sale of a
[financial instrument]’’ 518 or to
language in Appendix B indicating that
the Agencies may assess certain factors
and criteria at different levels, including
a ‘‘single significant transaction.’’ 519
With respect to the burdens of a
transaction-by-transaction analysis,
some commenters noted that banking
entities can engage in a large volume of
market-making transactions daily,
which would make it burdensome to
apply the exemption to each trade.520 A
few commenters indicated that, even if
the Agencies did not intend to require
transaction-by-transaction analysis, the
proposed rule’s language can be read to
imply such a requirement. These
commenters indicated that ambiguity on
this issue could have a chilling effect on
market making or could allow some
examiners to rigidly apply the
requirements of the exemption on a
trade-by-trade basis.521 Other
commenters indicated that it would be
difficult to determine whether a
particular trade was or was not a
market-making trade without
consideration of the relevant unit’s
overall activities.522 One commenter
elaborated on this point by stating that
516 See
Paul Volcker.
Wellington; SIFMA et al. (Prop. Trading)
(Feb. 2012); Barclays; Goldman (Prop. Trading);
HSBC; Fixed Income Forum/Credit Roundtable;
ACLI (Feb. 2012); PUC Texas; ERCOT; Invesco. See
also IAA (stating that it is unclear whether the
requirements must be applied on a transaction-bytransaction basis or if compliance with the
requirements is based on overall activities). This
issue is addressed in Part IV.A.3.c.1.c., infra.
518 See, e.g., Barclays; SIFMA et al. (Prop.
Trading) (Feb. 2012). As explained above, the term
‘‘covered financial position’’ from the proposal has
been replaced by the term ‘‘financial instrument’’ in
the final rule. Because the types of instruments
included in both definitions are identical, the term
‘‘financial instrument’’ is used throughout this Part.
519 See, e.g., Goldman (Prop. Trading);
Wellington.
520 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Barclays (stating that ‘‘hundreds or
thousands of trades can occur in a single day in a
single trading unit’’).
521 See, e.g., ICI (Feb. 2012); Barclays; Goldman
(Prop. Trading).
522 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Goldman (Prop. Trading).
517 See
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‘‘an analysis that seeks to characterize
specific transactions as either market
making. . . or prohibited activity does
not accord with the way in which
modern trading units operate, which
generally view individual positions as a
bundle of characteristics that contribute
to their complete portfolio.’’ 523 This
commenter noted that a position entered
into as part of market making-related
activities may serve multiple functions
at one time, such as responding to
customer demand, hedging a risk, and
building inventory. The commenter also
expressed concern that individual
transactions or positions may not be
severable or separately identifiable as
serving a market-making purpose.524
Two commenters suggested that the
requirements in the market-making
exemption be applied at the portfolio
level rather than the trade level.525
Moreover, commenters also set forth
their views on the organizational level
at which the requirements of the
proposed market-making exemption
should apply.526 The proposed
exemption generally applied
requirements to a ‘‘trading desk or other
organizational unit’’ of a banking entity.
In response to this proposed approach,
commenters stated that compliance
should be assessed at each trading desk
or aggregation unit 527 or at each trading
unit.528
523 SIFMA
et al. (Prop. Trading) (Feb. 2012).
id. (suggesting that the Agencies ‘‘give full
effect to the statutory intent to allow market making
by viewing the permitted activity on a holistic
basis’’).
525 See ACLI (Feb. 2012); Fixed Income Forum/
Credit Roundtable.
526 See Wellington; Morgan Stanley; SIFMA et al.
(Prop. Trading) (Feb. 2012); ACLI (Feb. 2012); Fixed
Income Forum/Credit Roundtable. The Agencies
address this topic in Part IV.A.3.c.1.c., infra.
527 See Wellington. This commenter did not
provide greater specificity about how it would
define ‘‘trading desk’’ or ‘‘aggregation unit.’’ See id.
528 See Morgan Stanley (stating that ‘‘trading
unit’’ should be defined as ‘‘each organizational
unit that is used to structure and control the
aggregate risk-taking activities and employees that
are engaged in the coordinated implementation of
a customer-facing revenue generation strategy and
that participate in the execution of any covered
trading activity’’); SIFMA et al. (Prop. Trading)
(Feb. 2012). One of these commenters discussed its
suggested definition of ‘‘trading unit’’ in the context
of the proposed requirement to record and report
certain quantitative measurements, but it is unclear
that the commenter was also suggesting that this
definition be used for purposes of the marketmaking exemption. For example, this commenter
expressed support for a multi-level approach to
defining ‘‘trading unit,’’ and it is not clear how a
definition that captures multiple organizational
levels across a banking organization would work in
the context of the market-making exemption. See
SIFMA et al. (Prop. Trading) (Feb. 2012) (suggested
that ‘‘trading unit’’ be defined ‘‘at a level that
presents its activities in the context of the whole’’
and noting that the appropriate level may differ
depending on the structure of the banking entity).
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Several commenters suggested
alternative or additive means of
implementing the statutory exemption
for market making-related activity.529
Commenters’ recommended approaches
varied, but a number of commenters
requested approaches involving one or
more of the following elements: (i) Safe
harbors,530 bright lines,531 or
presumptions of compliance with the
exemption based on the existence of
certain factors (e.g., compliance
program, metrics, general customer
focus or orientation, providing liquidity,
and/or exchange registration as a market
maker); 532 (ii) a focus on metrics or
other objective factors; 533 (iii) guidance
on permitted market making-related
activity, rather than rule
requirements; 534 (iv) risk management
structures and/or risk limits; 535 (v)
adding a new customer-facing criterion
or focusing on client-related
activities; 536 (vi) capital and liquidity
529 See, e.g., Wellington; Japanese Bankers Ass’n.;
Prof. Duffie; IR&M; G2 FinTech; MetLife; NYSE
Euronext; Anthony Flynn and Koral Fusselman; IIF;
CalPERS; SIFMA et al. (Prop. Trading) (Feb. 2012);
Sens. Merkley & Levin (Feb. 2012); Shadow Fin.
Regulatory Comm.; John Reed; Prof. Richardson;
Credit Suisse (Seidel); JPMC; Morgan Stanley;
Barclays; Goldman (Prop. Trading); BoA; Citigroup
(Feb. 2012); STANY; ICE; BlackRock; Johnson &
Prof. Stiglitz; Fixed Income Forum/Credit
Roundtable; ACLI (Feb. 2012); Wells Fargo (Prop.
Trading); WR Hambrecht; Vanguard; Capital Group;
PUC Texas; SSgA (Feb. 2012); PNC et al.; Fidelity;
Occupy; AFR et al. (Feb. 2012); Invesco; ISDA (Feb.
2012); Stephen Roach; Oliver Wyman (Feb. 2012).
The Agencies respond to these comments in Part
IV.A.3.b.3., infra.
530 See, e.g., Sens. Merkley & Levin (Feb. 2012);
John Reed; Prof. Richardson; Johnson & Prof.
Stiglitz; Capital Group; Invesco; BDA (Feb. 2012)
(Oct. 2012) (suggesting a safe harbor for any trading
desk that effects more than 50 percent of its
transactions through sales representatives).
531 See, e.g., Flynn & Fusselman; Prof. Colesanti
et al.
532 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); IIF; NYSE Euronext; Credit Suisse (Seidel);
JPMC; Barclays; BoA; Wells Fargo (Prop. Trading)
(suggesting that the rule: (i) Provide a general grant
of authority to engage in any transactions entered
into as part of a banking entity’s market-making
business, where ‘‘market making’’ is defined as ‘‘the
business of being willing to facilitate customer
purchases and sales of [financial instruments] as an
intermediary over time and in size, including by
holding positions in inventory;’’ and (ii) allow
banking entities to monitor compliance with this
exemption internally through their compliance and
risk management infrastructure); PNC et al.; Oliver
Wyman (Feb. 2012).
533 See, e.g., Goldman (Prop. Trading); Morgan
Stanley; Barclays; Wellington; CalPERS; BlackRock;
SSgA (Feb. 2012); Invesco.
534 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (suggesting that this guidance could be
incorporated in banking entities’ policies and
procedures for purposes of complying with the rule,
in addition to the establishment of risk limits,
controls, and metrics); JPMC; BoA; PUC Texas;
SSgA (Feb. 2012); PNC et al.; Wells Fargo (Prop.
Trading).
535 See, e.g., Japanese Bankers Ass’n.; Citigroup
(Feb. 2012).
536 See, e.g., Morgan Stanley; Stephen Roach.
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requirements; 537 (vii) development of
individualized plans for each banking
entity, in coordination with
regulators; 538 (viii) ring fencing
affiliates engaged in market makingrelated activity; 539 (ix) margin
requirements; 540 (x) a compensationfocused approach; 541 (xi) permitting all
swap dealing activity; 542 (xii) additional
provisions regarding material conflicts
of interest and high-risk assets and
trading strategies; 543 and/or (xiii)
making the exemption as broad as
possible under the statute.544
b. Comments Regarding the Potential
Market Impact of the Proposed
Exemption
As discussed above, several
commenters stated that the proposed
rule would impact a banking entity’s
ability to engage in market makingrelated activity. Many of these
commenters represented that, as a
result, the proposed exemption would
likely result in reduced liquidity,545
537 See, e.g., Prof. Duffie; CalPERS; STANY; ICE;
Vanguard; Capital Group.
538 See MetLife; Fixed Income Forum/Credit
Roundtable; ACLI (Feb. 2012).
539 See, e.g., Prof. Duffie; Shadow Fin. Regulatory
Comm. See also Wedbush.
540 See WR Hambrecht.
541 See G2 FinTech.
542 See ISDA (Feb. 2012); ISDA (Apr. 2012).
543 See Sens. Merkley & Levin (Feb. 2012) (stating
that the exemption should expressly mention the
conflicts provision and provide examples to warn
against particular conflicts, such as recommending
clients buy poorly performing assets in order to
remove them from the banking entity’s book or
attempting to move market prices in favor of trading
positions a banking entity has built up in order to
make a profit); Stephen Roach (suggesting that the
exemption integrate the limitations on permitted
activities).
544 See Fidelity (stating that the exemption needs
to be as broad as possible to account for customerfacing principal trades, block trades, and market
making in OTC derivatives). See also STANY
(stating that it is better to make the exemption too
broad than too narrow).
545 See, e.g., AllianceBernstein; Rep. Bachus et al.
(Dec. 2011); EMTA; NASP; Wellington; Japanese
Bankers Ass’n.; Sen. Hagan; Prof. Duffie; Investure;
Standish Mellon; IR&M; MetLife; Lord Abbett;
Commissioner Barnier; Quebec; IIF; Sumitomo
Trust; Liberty Global; NYSE Euronext; CIEBA;
EFAMA; SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); JPMC; Morgan Stanley;
Barclays; Goldman (Prop. Trading); BoA; Citigroup
(Feb. 2012); STANY; ICE; BlackRock; SIFMA (Asset
Mgmt.) (Feb. 2012); BDA (Feb. 2012); Putnam;
Fixed Income Forum/Credit Roundtable; Western
Asset Mgmt.; ACLI (Feb. 2012); IAA; CME Group;
Wells Fargo (Prop. Trading); Abbott Labs et al. (Feb.
14, 2012); Abbott Labs et al. (Feb. 21, 2012); T.
Rowe Price; Australian Bankers Ass’n. (Feb. 2012);
FEI; AFMA; Sen. Carper et al.; PUC Texas; ERCOT;
IHS; Columbia Mgmt.; SSgA (Feb. 2012); PNC et al.;
Eaton Vance; Fidelity; ICI (Feb. 2012); British
Bankers’ Ass’n.; Comm. on Capital Markets
Regulation; Union Asset; Sen. Casey; Oliver Wyman
(Dec. 2011); Oliver Wyman (Feb. 2012) (providing
estimated impacts on asset valuation, borrowing
costs, and transaction costs in the corporate bond
market based on hypothetical liquidity reduction
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wider bid-ask spreads,546 increased
market volatility,547 reduced price
discovery or price transparency,548
increased costs of raising capital or
higher financing costs,549 greater costs
for investors or consumers,550 and
scenarios); Thakor Study. The Agencies respond to
comments regarding the potential market impact of
the rule in Part IV.A.3.b.3., infra.
546 See, e.g., AllianceBernstein; Wellington;
Investure; Standish Mellon; MetLife; Lord Abbett;
Barclays; Goldman (Prop. Trading); Citigroup (Feb.
2012); BlackRock; Putnam; ACLI (Feb. 2012);
Abbott Labs et al. (Feb. 14, 2012); Abbott Labs et
al. (Feb. 21, 2012); T. Rowe Price; Sen. Carper et
al.; IHS; Columbia Mgmt.; ICI (Feb. 2012) British
Bankers’ Ass’n.; Comm. on Capital Markets
Regulation; Thakor Study (stating that section 13 of
the BHC Act will likely result in higher bid-ask
spreads by causing at least some retrenchment of
banks from market making, resulting in fewer
market makers and less competition).
547 See, e.g., Wellington; Prof. Duffie; Standish
Mellon; Lord Abbett; IIF; SIFMA et al. (Prop.
Trading) (Feb. 2012); Barclays; Goldman (Prop.
Trading); BDA (Feb. 2012); IHS; FTN; IAA; Wells
Fargo (Prop. Trading); T. Rowe Price; Columbia
Mgmt.; SSgA (Feb. 2012); Eaton Vance; British
Bankers’ Ass’n.; Comm. on Capital Markets
Regulation.
548 See, e.g., Prof. Duffie (arguing that, for
example, ‘‘during the financial crisis of 2007–2009,
the reduced market making capacity of major dealer
banks caused by their insufficient capital levels
resulted in dramatic downward distortions in
corporate bond prices’’); IIF; Barclays; IAA;
Vanguard; Wellington; FTN.
549 See, e.g., AllianceBernstein; Chamber (Dec.
2011); Members of Congress (Dec. 2011);
Wellington; Sen. Hagan; Prof. Duffie; IR&M;
MetLife; Lord Abbett; Liberty Global; NYSE
Euronext; SIFMA et al. (Prop. Trading) (Feb. 2012);
NCSHA; ASF (Feb. 2012) (stating that ‘‘[f]ailure to
permit the activities necessary for banking entities
to act in [a] market-making capacity [in assetbacked securities] would have a dramatic adverse
effect on the ability of securitizers to access the
asset-backed securities markets and thus to obtain
the debt financing necessary to ensure a vibrant
U.S. economy’’); Credit Suisse (Seidel); JPMC;
Morgan Stanley; Barclays; Goldman (Prop. Trading);
BoA; Citigroup (Feb. 2012); STANY; BlackRock;
Chamber (Feb. 2012); IHS; BDA (Feb. 2012); Fixed
Income Forum/Credit Roundtable; ACLI (Feb.
2012); Wells Fargo (Prop. Trading); Abbott Labs et
al. (Feb. 14, 2012); Abbott Labs et al. (Feb. 21,
2012); T. Rowe Price; FEI; AFMA; SSgA (Feb. 2012);
PNC et al.; ICI (Feb. 2012); British Bankers’ Ass’n.;
Oliver Wyman (Dec. 2011); Oliver Wyman (Feb.
2012); GE (Feb. 2012); Thakor Study (stating that
when a firm’s cost of capital goes up, it invests
less—resulting in lower economic growth and lower
employment—and citing supporting data indicating
that a 1 percent increase in the cost of capital would
lead to a $55 to $82.5 billion decline in aggregate
annual capital spending by U.S. nonfarm firms and
job losses between 550,000 and 1.1 million per year
in the nonfarm sector). One commenter further
noted that a higher cost of capital can lead a firm
to make riskier, short-term investments. See Thakor
Study.
550 See, e.g., Wellington; Standish Mellon; IR&M;
MetLife; Lord Abbett; NYSE Euronext; CIEBA;
Barclays; Goldman (Prop. Trading); BoA; Citigroup
(Feb. 2012); STANY; ICE; BlackRock; Fixed Income
Forum/Credit Roundtable; ACLI (Feb. 2012); IAA;
Abbott Labs et al. (Feb. 14, 2012); Abbott Labs et
al. (Feb. 21, 2012); T. Rowe Price; Vanguard;
Australian Bankers Ass’n. (Feb. 2012); FEI; Sen.
Carper et al.; Columbia Mgmt.; SSgA (Feb. 2012);
ICI (Feb. 2012); Comm. on Capital Markets
Regulation; TMA Hong Kong; Sen. Casey; IHS;
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slower execution times.551 Some
commenters expressed particular
concern about potential impacts on
institutional investors (e.g., mutual
funds and pension funds) 552 or on small
or midsized companies.553 A number of
commenters discussed the
interrelationship between primary and
secondary market activity and indicated
that restrictions on market making
would impact the underwriting
process.554
A few commenters expressed the view
that reduced liquidity would not
Oliver Wyman (Dec. 2011); Oliver Wyman (Feb.
2012); Thakor Study.
551 See, e.g., Barclays; FTN; Abbott Labs et al.
(Feb. 14, 2012); Abbott Labs et al. (Feb. 21, 2012).
552 See, e.g., AllianceBernstein (stating that, to the
extent the rule reduces liquidity provided by
market makers, open end mutual funds that are
largely driven by the need to respond to both
redemptions and subscriptions will be immediately
impacted in terms of higher trading costs);
Wellington (indicating that periods of extreme
market stress are likely to exacerbate costs and
challenges, which could force investors such as
mutual funds and pension funds to accept
distressed prices to fund redemptions or pay
current benefits); Lord Abbett (stating that certain
factors, such as reduced bank capital to support
market-making businesses and economic
uncertainty, have already reduced liquidity and
caused asset managers to have an increased
preference for highly liquid credits and expressing
concern that, if section 13 of the BHC Act further
reduces liquidity, then: (i) Asset managers’
increased preference for highly liquid credit could
lead to unhealthy portfolio concentrations, and (ii)
asset managers will maintain a larger cash cushion
in portfolios that may be subject to redemption,
which will likely result in investors getting poorer
returns); EFAMA; BlackRock (stating that
investment decisions are heavily dependent on a
liquidity factor input, so as liquidity dissipates,
investment strategies become more limited and
returns to investors are diminished by wider
spreads and higher transaction costs); CFA Inst.
(noting that a mutual fund that tries to liquidate
holdings to meet redemptions may have difficulty
selling at acceptable prices, thus impairing the
fund’s NAV for both redeeming investors and for
those that remain in the fund); Putnam; Fixed
Income Forum/Credit Roundtable; ACLI; T. Rowe
Price; Vanguard; IAA; FEI; Sen. Carper et al.;
Columbia Mgmt.; ICI (Feb. 2012); Invesco; Union
Asset; Standish Mellon; Morgan Stanley; SIFMA
(Asset Mgmt.) (Feb. 2012).
553 See, e.g., CIEBA (stating that for smaller
issuers in particular, market makers need to have
incentives to make markets, and the proposal
removes important incentives); ACLI (indicating
that lower liquidity will most likely result in higher
costs for issuers of debt and, for lesser known or
lower quality issuers, this cost may be significant
and in some cases prohibitive because the cost will
vary depending on the credit quality of the issuer,
the amount of debt it has in the market, and the
maturity of the security); PNC et al. (expressing
concern that a regional bank’s market-making
activity for small and middle market customers is
more likely to be inappropriately characterized as
impermissible proprietary trading due to lower
trading volume involving less liquid securities);
Morgan Stanley; Chamber (Feb. 2012); Abbott Labs
et al. (Feb. 14, 2012); Abbott Labs et al. (Feb. 21,
2012); FEI; ICI (Feb. 2012); TMA Hong Kong; Sen.
Casey.
554 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; RBC; NYSE Euronext; Credit Suisse (Seidel).
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necessarily be a negative result.555 For
example, two commenters noted that
liquidity is vulnerable to liquidity
spirals, in which a high level of market
liquidity during one period feeds a
sharp decline in liquidity during the
next period by initially driving asset
prices upward and supporting increased
leverage. The commenters explained
that liquidity spirals lead to ‘‘fire sales’’
by market speculators when events
reveal that assets are overpriced and
speculators must sell their assets to
reduce their leverage.556 According to
another commenter, banking entities’
access to the safety net allows them to
distort market prices and, arguably,
produce excess liquidity. The
commenter further represented that it
would be preferable to allow the
discipline of the market to choose the
pricing of securities and the amount of
liquidity.557 Some commenters cited an
economic study indicating that the U.S.
financial system has become less
efficient in generating economic growth
in recent years, despite increased
trading volumes.558
Some commenters stated that it is
unlikely the proposed rule would result
in the negative market impacts
identified above, such as reduced
market liquidity.559 For example, a few
commenters stated that other market
participants, who are not subject to
section 13 of the BHC Act, may enter the
market or increase their trading
activities to make up for any reduction
in banking entities’ market-making
555 See, e.g., Paul Volcker; AFR et al. (Feb. 2012);
Public Citizen; Prof. Richardson; Johnson & Prof.
Stiglitz; Better Markets (Feb. 2012); Prof. Johnson.
556 See AFR et al. (Feb. 2012); Public Citizen. See
also Paul Volcker (stating that at some point, greater
liquidity, or the perception of greater liquidity, may
encourage more speculative trading).
557 See Prof. Richardson.
558 See, e.g., Johnson & Prof. Stiglitz (citing
Thomas Phillippon, Has the U.S. Finance Industry
Become Less Efficient?, NYU Working Paper, Nov.
2011); AFR et al. (Feb. 2012); Public Citizen; Better
Markets (Feb. 2012); Prof. Johnson.
559 See, e.g., Sens. Merkley & Levin (Feb. 2012)
(stating that there is no convincing, independent
evidence that the rule would increase trading costs
or reduce liquidity, and the best evidence available
suggests that the buy-side firms would greatly
benefit from the competitive pressures that
transparency can bring); Better Markets (Feb. 2012)
(‘‘Industry’s claim that [section 13 of the BHC Act]
will ‘reduce market liquidity, capital formation, and
credit availability, and thereby hamper economic
growth and job creation’ disregard the fact that the
financial crisis did more damage to those concerns
than any rule or reform possibly could.’’); Profs.
Stout & Hastings; Prof. Johnson; Occupy; Public
Citizen; Profs. Admati & Pfleiderer; Better Markets
(June 2012); AFR et al. (Feb. 2012). One commenter
stated that the proposed rule would improve market
liquidity, efficiency, and price transparency. See
Alfred Brock.
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activity or other trading activity.560 For
instance, one of these commenters
suggested that the revenue and profits
from market making will be sufficient to
attract capital and competition to that
activity.561 In addition, one commenter
expressed the view that prohibiting
proprietary trading may support more
liquid markets by ensuring that banking
entities focus on providing liquidity as
market makers, rather than taking
liquidity from the market in the course
of ‘‘trading to beat’’ institutional buyers
like pension funds, university
endowments, and mutual funds.562
Another commenter stated that, while
section 13 of the BHC Act may
temporarily reduce trading volume and
excessive liquidity at the peak of market
bubbles, it should increase the long-run
stability of the financial system and
render genuine liquidity and credit
availability more reliable over the long
term.563
Other commenters, however,
indicated that it is uncertain or unlikely
that non-banking entities will enter the
market or increase their trading
activities, particularly in the short
term.564 For example, one commenter
noted the investment that banking
entities have made in infrastructure for
trading and compliance would take
smaller or new firms years and billions
of dollars to replicate.565 Another
commenter questioned whether other
market participants, such as hedge
funds, would be willing to dedicate
capital to fully serving customer needs,
which is required to provide ongoing
liquidity.566 One commenter stated that
even if non-banking entities move in to
560 See, e.g., Sens. Merkley & Levin (Feb. 2012);
Prof. Richardson; Better Markets (Feb. 2012); Profs.
Stout & Hastings; Prof. Johnson; Occupy; Public
Citizen; Profs. Admati & Pfleiderer; Better Markets
(June 2012). Similarly, one commenter indicated
that non-banking entity market participants could
fill the current role of banking entities in the market
if implementation of the rule is phased in. See ACLI
(Feb. 2012).
561 See Better Markets (Feb. 2012).
562 See Prof. Johnson.
563 See AFR et al. (Feb. 2012).
564 See, e.g., Wellington; Prof. Duffie; Investure;
IIF; Liberty Global; SIFMA et al. (Prop. Trading)
(Feb. 2012); Credit Suisse (Seidel); JPMC; Morgan
Stanley; Barclays; BoA; STANY; SIFMA (Asset
Mgmt.) (Feb. 2012); FTN; Western Asset Mgmt.;
IAA; PUC Texas; ICI (Feb. 2012); IIB/EBF; Invesco.
In addition, some commenters recognized that other
market participants are likely to fill banking
entities’ roles in the long term, but not in the short
term. See, e.g., ICFR; Comm. on Capital Markets
Regulation; Oliver Wyman (Feb. 2012).
565 See Oliver Wyman (Feb. 2012) (‘‘Major bankaffiliated market makers have large capital bases,
balance sheets, technology platforms, global
operations, relationships with clients, sales forces,
risk infrastructure, and management processes that
would take smaller or new dealers years and
billions of dollars to replicate.’’).
566 See SIFMA et al. (Prop. Trading) (Feb. 2012).
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replace lost trading activity from
banking entities, the value of the current
interdealer network among market
makers will be reduced due to the exit
of banking entities.567 Several
commenters expressed the view that
migration of market making-related
activities to firms outside the banking
system would be inconsistent with
Congressional intent and would have
potentially adverse consequences for the
safety and soundness of the U.S.
financial system.568
Many commenters requested
additional clarification on how the
proposed market-making exemption
would apply to certain asset classes and
markets or to particular types of market
making-related activities. In particular,
commenters requested greater clarity
regarding the permissibility of: (i)
interdealer trading,569 including trading
for price discovery purposes or to test
market depth; 570 (ii) inventory
management; 571 (iii) block positioning
activity; 572 (iv) acting as an authorized
participant or market maker in ETFs; 573
(v) arbitrage or other activities that
promote price transparency and
liquidity; 574 (vi) primary dealer
activity; 575 (vii) market making in
futures and options; 576 (viii) market
567 See
Thakor Study.
e.g., Prof. Duffie; Oliver Wyman (Feb.
making in new or bespoke products or
customized hedging contracts; 577 and
(ix) inter-affiliate transactions.578 As
discussed in more detail in Part
IV.B.2.c., a number of commenters
requested that the market-making
exemption apply to the restrictions on
acquiring or retaining an ownership
interest in a covered fund.579 Some
commenters stated that no other
activities should be considered
permitted market making-related
activity under the rule.580 In addition, a
few commenters requested clarification
that high-frequency trading would not
qualify for the market-making
exemption.581
3. Final Market-Making Exemption
After carefully considering comment
letters, the Agencies are adopting
certain refinements to the proposed
market-making exemption. The
Agencies are adopting a market-making
exemption that is consistent with the
statutory exemption for this activity and
designed to permit banking entities to
continue providing intermediation and
liquidity services. The Agencies note
that, while all market-making activity
should ultimately be related to the
intermediation of trading, whether
directly to individual customers through
bilateral transactions or more broadly to
568 See,
2012).
569 See, e.g., MetLife; SIFMA et al. (Prop. Trading)
(Feb. 2012); RBC; Credit Suisse (Seidel); JPMC;
BoA; ACLI (Feb. 2012); AFR et al. (Feb. 2012); ISDA
(Feb. 2012); Goldman (Prop. Trading); Oliver
Wyman (Feb. 2012).
570 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Chamber (Feb. 2012); Goldman (Prop. Trading).
571 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); Goldman (Prop.
Trading); MFA; RBC.
572 See infra Part IV.A.3.c.1.b.ii. (discussing
commenters’ requests for greater clarity regarding
the permissibility of block positioning activity).
573 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); BoA; ICI (Feb. 2012); ICI Global;
Vanguard; SSgA (Feb. 2012).
574 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); FTN; RBC; ISDA (Feb. 2012).
575 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); JPMC; Goldman (Prop. Trading); Banco de
´
Mexico; IIB/EBF.
576 See CME Group (requesting clarification that
the market-making exemption permits a banking
entity to engage in market making in exchangetraded futures and options because the dealer
registration requirement in § ll.4(b)(2)(iv) of the
proposed rule did not refer to such instruments and
stating that lack of an explicit exemption would
reduce market-making activities in these
instruments, which would decrease liquidity). But
See Johnson & Prof. Stiglitz (stating that the
Agencies should pay special attention to options
trading and other derivatives because they are
highly volatile assets that are difficult if not
impossible to effectively hedge, except through a
completely matched position, and suggesting that
options and similar derivatives may need to be
required to be sold only as riskless principal under
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§ ll.6(b)(1)(ii) of the proposed rule or
significantly limited through capital charges); Sens.
Merkley & Levin (Feb. 2012) (stating that asset
classes that are particularly hard to hedge, such as
options, should be given special attention under the
hedging exemption).
577 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); SIFMA (Asset Mgmt.) (Feb. 2012). Other
commenters, however, stated that banking entities
should be limited in their ability to rely on the
market-making exemption to conduct transactions
in bespoke or customized derivatives. See, e.g., AFR
et al. (Feb. 2012); Public Citizen.
578 See, e.g., Japanese Bankers Ass’n. (stating that
transactions with affiliates and subsidiaries and
related to hedging activities are a type of market
making-related activity or risk-mitigating hedging
activity that should be exempted by the rule);
SIFMA et al. (Prop. Trading) (Feb. 2012). According
to one of these commenters, inter-affiliate
transactions should be viewed as part of a
coordinated activity for purposes of determining
whether a banking entity qualifies for an
exemption. This commenter stated that, for
example, if a market maker shifts positions held in
inventory to an affiliate that is better able to manage
the risk of such positions, both the market maker
and its affiliate would be engaged in permitted
market making-related activity. This commenter
further represented that fitting the inter-affiliate
swap into the exemption may be difficult (e.g., one
of the affiliates entering into the swap may not be
holding itself out as a willing counterparty). See
SIFMA et al. (Prop. Trading) (Feb. 2012).
579 See, e.g., Cleary Gottlieb; JPMC; BoA; Credit
Suisse (Williams).
580 See, e.g., Occupy; Alfred Brock.
581 See, e.g., Occupy; AFR et al. (Feb. 2012);
Public Citizen; Johnson & Prof. Stiglitz; Sens.
Merkley & Levin (Feb. 2012); John Reed.
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a given marketplace, certain
characteristics of a market-making
business may differ among markets and
asset classes.582 The final rule is
intended to account for these
differences to allow banking entities to
continue to engage in market makingrelated activities by providing customer
intermediation and liquidity services
across markets and asset classes, if such
activities do not violate the statutory
limitations on permitted activities (e.g.,
by involving or resulting in a material
conflict of interest with a client,
customer, or counterparty) and are
conducted in conformance with the
exemption.
At the same time, the final rule
requires development and
implementation of trading, risk and
inventory limits, risk management
strategies, analyses of how the specific
market making-related activities are
designed not to exceed the reasonably
expected near term demands of
customers, compensation standards, and
monitoring and review requirements
that are consistent with market-making
activities.583 These requirements are
designed to distinguish exempt market
making-related activities from
impermissible proprietary trading. In
addition, these requirements are
designed to ensure that a banking entity
is aware of, monitors, and limits the
risks of its exempt activities consistent
with the prudent conduct of market
making-related activities.
As described in detail below, the final
market-making exemption consists of
the following elements:
• A framework that recognizes the
differences in market making-related
activities across markets and asset
582 Consistent with the FSOC study and the
proposal, the final rule recognizes that the precise
nature of a market maker’s activities often varies
depending on the liquidity, trade size, market
infrastructure, trading volumes and frequency, and
geographic location of the market for any particular
type of financial instrument. See Joint Proposal, 76
FR 68,870; CFTC Proposal, 77 FR 8356; FSOC study
(stating that ‘‘characteristics of permitted activities
in one market or asset class may not be the same
in another market (e.g., permitted activities in a
liquid equity securities market may vary
significantly from an illiquid over-the-counter
derivatives market)’’).
583 Certain of these requirements, like the
requirements to have risk and inventory limits, risk
management strategies, and monitoring and review
requirements were included in the enhanced
compliance program requirement in proposed
Appendix C, but were not separately included in
the proposed market-making exemption. Like the
statute, the proposed rule would have required that
market making-related activities be designed not to
exceed the reasonably expected near term demand
of clients, customers, or counterparties. The
Agencies are adding an explicit requirement in the
final rule that a trading desk conduct analyses of
customer demand for purposes of complying with
this statutory requirement.
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classes by establishing criteria that can
be applied based on the liquidity,
maturity, and depth of the market for
the particular type of financial
instrument.
• A general focus on analyzing the
overall ‘‘financial exposure’’ and
‘‘market-maker inventory’’ held by any
given trading desk rather than a
transaction-by-transaction analysis. The
‘‘financial exposure’’ reflects the
aggregate risks of the financial
instruments, and any associated loans,
commodities, or foreign exchange or
currency, held by a banking entity or its
affiliate and managed by a particular
trading desk as part of its market
making-related activities. The ‘‘marketmaker inventory’’ means all of the
positions, in the financial instruments
for which the trading desk stands ready
to make a market that are managed by
the trading desk, including the trading
desk’s open positions or exposures
arising from open transactions.584
• A definition of the term ‘‘trading
desk’’ that focuses on the operational
functionality of the desk rather than its
legal status, and requirements that apply
at the trading desk level of organization
within a single banking entity or across
two or more affiliates.585
• Five requirements for determining
whether a banking entity is engaged in
permitted market making-related
activities. Many of these criteria have
similarities to the factors included in
the proposed rule, but with important
modifications in response to comments.
These standards require that:
Æ The trading desk that establishes
and manages a financial exposure
routinely stands ready to purchase and
sell one or more types of financial
instruments related to its financial
exposure and is willing and available to
quote, buy and sell, or otherwise enter
into long and short positions in those
types of financial instruments for its
own account, in commercially
reasonable amounts and throughout
market cycles, on a basis appropriate for
the liquidity, maturity, and depth of the
market for the relevant types of financial
instruments; 586
Æ The amount, types, and risks of the
financial instruments in the trading
desk’s market-maker inventory are
designed not to exceed, on an ongoing
584 See infra Part IV.A.3.c.1.c.ii. See also final rule
§§ ll.4(b)(4), (5).
585 See infra Part IV.A.3.c.1.c.i. The term ‘‘trading
desk’’ is defined as ‘‘the smallest discrete unit of
organization of a banking entity that buys or sells
financial instruments for the trading account of the
banking entity or an affiliate thereof.’’ Final rule
§ ll.3(e)(13).
586 See final rule § ll.4(b)(2)(i); infra Part
IV.A.3.c.1.c.iii.
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5581
basis, the reasonably expected near term
demands of clients, customers, or
counterparties, as required by the
statute and based on certain factors and
analysis; 587
Æ The banking entity has established
and implements, maintains, and
enforces an internal compliance
program that is reasonably designed to
ensure its compliance with the marketmaking exemption, including
reasonably designed written policies
and procedures, internal controls,
analysis, and independent testing
identifying and addressing:
D The financial instruments each
trading desk stands ready to purchase
and sell in accordance with § ll
.4(b)(2)(i) of the final rule;
D The actions the trading desk will
take to demonstrably reduce or
otherwise significantly mitigate
promptly the risks of its financial
exposure consistent with its established
limits; the products, instruments, and
exposures each trading desk may use for
risk management purposes; the
techniques and strategies each trading
desk may use to manage the risks of its
market making-related activities and
inventory; and the process, strategies,
and personnel responsible for ensuring
that the actions taken by the trading
desk to mitigate these risks are and
continue to be effective; 588
D Limits for each trading desk, based
on the nature and amount of the trading
desk’s market making-related activities,
including factors used to determine the
reasonably expected near term demands
of clients, customers, or counterparties,
on: the amount, types, and risks of its
market-maker inventory; the amount,
types, and risks of the products,
instruments, and exposures the trading
desk uses for risk management
purposes; the level of exposures to
relevant risk factors arising from its
financial exposure; and the period of
time a financial instrument may be held;
D Internal controls and ongoing
monitoring and analysis of each trading
desk’s compliance with its limits; and
D Authorization procedures,
including escalation procedures that
587 See final rule § ll.4(b)(2)(ii); infra Part
IV.A.3.c.2.c. In addition, the Agencies are adopting
a definition of the terms ‘‘client,’’ ‘‘customer,’’ and
‘‘counterparty’’ in § ll.4(b)(3) of the final rule.
588 Routine market making-related risk
management activity by a trading desk is permitted
under the market-making exemption and, provided
the standards of the exemption are met, is not
required to separately meet the requirements of the
hedging exemption. The circumstances under
which risk management activity relating to the
trading desk’s financial exposure is permitted under
the market-making exemption or must separately
comply with the hedging exemption are discussed
in more detail in Parts IV.A.3.c.1.c.ii. and
IV.A.3.c.4., infra.
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require review and approval of any
trade that would exceed a trading desk’s
limit(s), demonstrable analysis that the
basis for any temporary or permanent
increase to a trading desk’s limit(s) is
consistent with the requirements of the
market-making exemption, and
independent review of such
demonstrable analysis and approval; 589
Æ To the extent that any limit
identified above is exceeded, the trading
desk takes action to bring the trading
desk into compliance with the limits as
promptly as possible after the limit is
exceeded; 590
Æ The compensation arrangements of
persons performing market makingrelated activities are designed not to
reward or incentivize prohibited
proprietary trading; 591 and
Æ The banking entity is licensed or
registered to engage in market makingrelated activities in accordance with
applicable law.592
• The use of quantitative
measurements to highlight activities
that warrant further review for
compliance with the exemption.593 As
discussed further in Part IV.C.3., the
Agencies have reduced some of the
compliance burdens by adopting a more
tailored subset of metrics than was
proposed to better focus on those
metrics that the Agencies believe are
most germane to the evaluation of the
activities that firms conduct under the
market-making exemption.
In refining the proposed approach to
implementing the statute’s marketmaking exemption, the Agencies closely
considered the various alternative
approaches suggested by
commenters.594 However, like the
proposed approach, the final marketmaking exemption continues to adhere
to the statutory mandate that provides
for an exemption to the prohibition on
proprietary trading for market makingrelated activities. Therefore, the final
rule focuses on providing a framework
for assessing whether trading activities
are consistent with market making. The
Agencies believe this approach is
589 See final rule § ll.4(b)(2)(iii); infra Part
IV.A.3.c.3.
590 See final rule § ll.4(b)(2)(iv).
591 See final rule § ll.4(b)(2)(v); infra Part
IV.A.3.c.5.
592 See final rule § ll.4(b)(2)(vi); infra Part
IV.A.3.c.6. As discussed further below, this
provision pertains to legal registration or licensing
requirements that may apply to an entity engaged
in market making-related activities, depending on
the facts and circumstances. This provision would
not require a banking entity to comply with
registration requirements that are not required by
law, such as discretionary registration with a
national securities exchange as a market maker on
that exchange.
593 See infra Part IV.C.3.
594 See supra Part IV.A.3.b.2.
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consistent with the statute 595 and
strikes an appropriate balance between
commenters’ desire for both clarity and
flexibility. For example, while a brightline or safe harbor based approach
would generally provide a high degree
of certainty about whether an activity
qualifies for the market-making
exemption, it would also provide less
flexibility to recognize the differences in
market-making activities across markets
and asset classes.596 In addition, any
bright-line approach would be more
likely to be subject to gaming and
avoidance as new products and types of
trading activities are developed than
other approaches to implementing the
market-making exemption.597 Although
a purely guidance-based approach
would provide greater flexibility, it
would also provide less clarity, which
could make it difficult for trading
personnel, internal compliance
personnel, and Agency supervisors and
examiners to determine whether an
activity complies with the rule and
would lead to an increased risk of
evasion of the statutory requirements.598
595 Certain approaches suggested by commenters,
such as relying solely on capital requirements,
requiring ring fencing, permitting all swap dealing
activity, or focusing solely on how traders are
compensated do not appear to be consistent with
the statutory language because they do not appear
to limit market making-related activity to that
which is designed not to exceed the reasonably
expected near term demands of clients, customers,
or counterparties, as required by the statute. See
Prof. Duffie; STANY; ICE; Shadow Fin. Regulatory
Comm.; ISDA (Feb. 2012); ISDA (Apr. 2012); G2
FinTech.
596 While an approach establishing a number of
safe harbors that are each tailored to a specific asset
class would address the need to recognize
differences across asset classes, such an approach
may also increase the complexity of the final rule.
Further, commenters did not provide sufficient
information to determine the appropriate
parameters of a safe harbor-based approach.
597 As noted above, a number of commenters
suggested the Agencies adopt a bright-line rule,
provide a safe harbor for certain types of activities,
or establish a presumption of compliance based on
certain factors. See, e.g., Sens. Merkley & Levin
(Feb. 2012); John Reed; Prof. Richardson; Johnson
& Prof. Stiglitz; Capital Group; Invesco; BDA (Oct.
2012); Flynn & Fusselman; Prof. Colesanti et al.;
SIFMA et al. (Prop. Trading) (Feb. 2012); IIF; NYSE
Euronext; Credit Suisse (Seidel); JPMC; Barclays;
BoA; Wells Fargo (Prop. Trading); PNC et al.; Oliver
Wyman (Feb. 2012). Many of these commenters
expressed general concern that the proposed
market-making exemption may create uncertainty
for individual traders engaged in market makingrelated activity and suggested that their proposed
approach would alleviate such concern. The
Agencies believe that the enhanced focus on risk
and inventory limits for each trading desk (which
must be tied to the near term customer demand
requirement) and the clarification that the final
market-making exemption does not require a tradeby-trade analysis should address concerns about
individual traders having to assess whether they are
complying with the market-making exemption on a
trade-by-trade basis.
598 Several commenters suggested a guidancebased approach, rather than requirements in the
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Some commenters suggested an
approach to implementing the marketmaking exemption that would focus on
metrics or other objective factors.599 As
discussed below, a number of
commenters expressed support for using
the metrics as a tool to monitor trading
activity and not to determine
compliance with the rule.600 While the
Agencies agree that quantitative
measurements are useful for purposes of
monitoring a trading desk’s activities
and are requiring certain banking
entities to calculate, record, and report
quantitative measurements to the
Agencies in the final rule, the Agencies
do not believe that quantitative
measurements should be used as a
dispositive tool for determining
compliance with the market-making
exemption.601
In response to two commenters’
request that the final rule focus on a
banking entity’s risk management
structures or risk limits and not on
attempting to define market-making
activities,602 the Agencies do not believe
that management of risk, on its own, is
sufficient to differentiate permitted
market making-related activities from
impermissible proprietary trading. For
example, the existence of a risk
management framework or risk limits,
while important, would not ensure that
a trading desk is acting as a market
maker by engaging in customer-facing
activity and providing intermediation
and liquidity services.603 The Agencies
also decline to take an approach to
implementing the market-making
exemption that would require the
development of individualized plans for
each banking entity in coordination
with the Agencies, as suggested by a few
final rule. See, e.g., SIFMA et al. (Prop. Trading)
(Feb. 2012) (suggesting that this guidance could
then be incorporated in banking entities’ policies
and procedures for purposes of complying with the
rule, in addition to the establishment of risk limits,
controls, and metrics); JPMC; BoA; PUC Texas;
SSgA (Feb. 2012); PNC et al.; Wells Fargo (Prop.
Trading).
599 See, e.g., Goldman (Prop. Trading); Morgan
Stanley; Barclays; Wellington; CalPERS; BlackRock;
SSgA (Feb. 2012); Invesco.
600 See infra Part IV.C.3. (discussing the final
rule’s metrics requirement). See SIFMA et al. (Prop.
Trading) (Feb. 2012); Wells Fargo (Prop. Trading);
RBC; ICI (Feb. 2012); Occupy (stating that there are
serious limits to the capabilities of the metrics and
the potential for abuse and manipulation of the
input data is significant); Alfred Brock.
601 See infra Part IV.C.3. (discussing the final
metrics requirement).
602 See, e.g., Japanese Bankers Ass’n.; Citigroup
(Feb. 2012).
603 However, as discussed below, the Agencies
believe risk limits can be a useful tool when they
must account for the nature and amount of a
particular trading desk’s market making-related
activities, including the reasonably expected near
term demands of clients, customers, or
counterparties.
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commenters.604 The Agencies believe it
is useful to establish a consistent
framework that will apply to all banking
entities to reduce the potential for
unintended competitive impacts that
could arise if each banking entity is
subject to an individualized plan that is
tailored to its specific organizational
structure and trading activities and
strategies.
Although the Agencies are not in the
final rule modifying the basic structure
of the proposed market-making
exemption, certain general items
suggested by commenters, such as
enhanced compliance program elements
and risk limits, have been incorporated
in the final rule text for the marketmaking exemption, instead of a separate
appendix.605 Moreover, as described
below, the final market-making
exemption includes specific substantive
changes in response to a wide variety of
commenter concerns.
The Agencies understand that the
economics of market making—and
financial intermediation in general—
require a market maker to be active in
markets. In determining the appropriate
scope of the market-making exemption,
the Agencies have been mindful of
commenters’ views on market making
and liquidity. Several commenters
stated that the proposed rule would
impact a banking entity’s ability to
engage in market making-related
activity, with corresponding reductions
in market liquidity.606 However,
604 See MetLife; Fixed Income Forum/Credit
Roundtable; ACLI (Feb. 2012).
605 The Agencies are not, however, adding certain
additional requirements suggested by commenters,
such as a new customer-facing criterion, margin
requirements, or additional provisions regarding
material conflicts of interest or high-risk assets or
trading strategies. See, e.g., Morgan Stanley;
Stephen Roach; WR Hambrecht; Sens. Merkley &
Levin (Feb. 2012). The Agencies believe that the
final rule includes sufficient requirements to ensure
that a trading desk relying on the market-making
exemption is engaged in customer-facing activity
(for example, the final rule requires the trading desk
to stand ready to buy and sell a type of financial
instrument as market maker and that the trading
desk’s market-maker inventory is designed not to
exceed the reasonably expected near term demands
of clients, customers, or counterparties). The
Agencies decline to include margin requirements in
the final exemption because banking entities are
currently subject to a number of different margin
requirements, including those applicable to, among
others: SEC-registered broker-dealers; CFTCregistered swap dealers; SEC-registered securitybased swap dealers: And foreign dealer entities.
Further, the Agencies are not providing new
requirements regarding material conflicts of interest
and high-risk assets and trading strategies in the
market-making exemption because the Agencies
believe these issues are adequately addressed in
§ ll.7 of the final rule. The limitations in § ll
.7 will apply to market making-related activities
and all other exempted activities.
606 See supra note 545 and accompanying text.
The Agencies acknowledge that reduced liquidity
can be costly. One commenter provided estimated
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commenters disagreed about whether
reduced liquidity would be beneficial or
detrimental to the market, or if any such
reductions would even materialize.607
Many commenters stated that reduced
liquidity could lead to other negative
market impacts, such as wider spreads,
higher transaction costs, greater market
volatility, diminished price discovery,
and increased cost of capital.
The Agencies understand that market
makers play an important role in
providing and maintaining liquidity
throughout market cycles and that
restricting market-making activity may
result in reduced liquidity, with
corresponding negative market impacts.
For instance, absent a market maker
who stands ready to buy and sell,
investors may have to make large price
concessions or otherwise expend
resources searching for counterparties.
By stepping in to intermediate trades
and provide liquidity, market makers
thus add value to the financial system
by, for example, absorbing supply and
demand imbalances. This often means
taking on financial exposures, in a
principal capacity, to satisfy reasonably
expected near term customer demand,
as well as to manage the risks associated
with meeting such demand.
The Agencies recognize that, as noted
by commenters, liquidity can be
associated with narrower spreads, lower
transaction costs, reduced volatility,
greater price discovery, and lower costs
of capital.608 The Agencies agree with
these commenters that liquidity
provides important benefits to the
financial system, as more liquid markets
are characterized by competitive market
makers, narrow bid-ask spreads, and
frequent trading, and that a narrowly
tailored market-making exemption
could negatively impact the market by,
as described above, forcing investors to
make price concessions or unnecessarily
expend resources searching for
impacts on asset valuation, borrowing costs, and
transaction costs in the corporate bond market
based on certain hypothetical scenarios of reduced
market liquidity. This commenter noted that its
hypothetical liquidity shifts of 5, 10, and 15
percentile points were ‘‘necessarily arbitrary’’ but
judged ‘‘to be realistic potential outcomes of the
proposed rule.’’ Oliver Wyman (Feb. 2012). Because
the Agencies have made significant modifications to
the proposed rule in response to comments, the
Agencies believe this commenter’s concerns about
the market impacts of the proposed rule have been
substantially addressed.
607 As noted above, a few commenters stated that
reduced liquidity may provide certain benefits. See,
e.g., Paul Volcker; AFR et al. (Feb. 2012); Public
Citizen; Prof. Richardson; Johnson & Prof. Stiglitz;
Better Markets (Feb. 2012); Prof. Johnson. However,
a number of commenters stated that reduced
liquidity would have negative market impacts. See
supra note 545 and accompanying text.
608 See supra Part IV.A.3.b.2.b.
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5583
counterparties.609 For example, while
bid-ask spreads compensate market
makers for providing liquidity when
asset values are uncertain, under
competitive forces, dealers compete
with respect to spreads, thus lowering
their profit margins on a per trade basis
and benefitting investors.610 Volatility is
driven by both uncertainty about
fundamental value and the liquidity
needs of investors. When markets are
illiquid, participants may have to make
large price concessions to find a
counterparty willing to trade, increasing
the importance of the liquidity channel
for addressing volatility. If liquiditybased volatility is not diversifiable,
investors will require a risk premium for
holding liquidity risk, increasing the
cost of capital.611 Commenters
additionally suggested that the effects of
diminished liquidity could be
concentrated in securities markets for
small or midsize companies or for
lesser-known issuers, where trading is
already infrequent.612 Volume in these
609 See supra Part IV.A.3.b.2.b. As discussed
above, a few other commenters suggested that to the
extent liquidity is vulnerable to destabilizing
liquidity spirals, any reduced liquidity stemming
from section 13 of the BHC Act and its
implementing rules would not necessarily be a
negative result. See AFR et al. (Feb. 2012); Public
Citizen. See also Paul Volcker. These commenters
also suggested that the Agencies adopt stricter
conditions in the market-making exemption, as
discussed throughout this Part IV.A.3. However,
liquidity—essentially, the ease with which assets
can be converted into cash—is not destabilizing in
and of itself. Rather, liquidity spirals are a function
of how firms are funded. During market downturns,
when margin requirements tend to increase, firms
that fund their operations with leverage face higher
costs of providing liquidity; firms that run up
against their maximum leverage ratios may be
forced to retreat from market making, contributing
to the liquidity spiral. Viewed in this light, it is
institutional features of financial markets—in
particular, leverage—rather than liquidity itself that
contributes to liquidity spirals.
610 Wider spreads can be costly for investors. For
example, one commenter estimated that a 10 basis
point increase in spreads in the corporate bond
market would cost investors $29 billion per year.
See Wellington. Wider spreads can also be
particularly costly for open-end mutual funds,
which must trade in and out of the fund’s portfolio
holdings on a daily basis in order to satisfy
redemptions and subscriptions. See Wellington;
AllianceBernstein.
611 A higher cost of capital increases financing
costs and translates into reduced capital
investment. While one commenter estimated that a
one percent increase in the cost of capital would
lead to a $55 to $82.5 billion decline in capital
investments by U.S. nonfarm firms, the Agencies
cannot independently verify these potential costs.
Further, this commenter did not indicate what
aspect of the proposed rule could cause a one
percent increase in the cost of capital. See Thakor
Study. In any event, the Agencies have made
significant changes to the proposed approach to
implementing the market-making exemption that
should help address this commenter’s concern.
612 See, e.g., CIEBA; ACLI; PNC et al.; Morgan
Stanley; Chamber (Feb. 2012); Abbott Labs et al.
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markets can be low, increasing the
inventory risk of market makers. The
Agencies recognize that, if the final rule
creates disincentives for banking
entities to provide liquidity, these low
volume markets may be impacted first.
As discussed above, the Agencies
received several comments suggesting
that the negative consequences
associated with reduced liquidity would
be unlikely to materialize under the
proposed rule. For example, a few
commenters stated that non-bank
financial intermediaries, who are not
subject to section 13 of the BHC Act,
may increase their market-making
activities in response to any reduction
in market making by banking entities, a
topic the Agencies discuss in more
detail below.613 In addition, some
commenters suggested that the
restrictions on proprietary trading
would support liquid markets by
encouraging banking entities to focus on
financial intermediation activities that
supply liquidity, rather than proprietary
trades that demand liquidity, such as
speculative trades or trades that frontrun institutional investors.614 The
statute prohibits proprietary trading
activity that is not exempted. As such,
the termination of nonexempt
proprietary trading activities of banking
entities may lead to some general
reductions in liquidity of certain asset
classes. Although the Agencies cannot
say with any certainty, there is good
reason to believe that to a significant
extent the liquidity reductions of this
type may be temporary since the statute
does not restrict proprietary trading
activities of other market participants.
Thus, over time, non-banking entities
may provide much of the liquidity that
is lost by restrictions on banking
entities’ trading activities. If so,
eventually, the detrimental effects of
increased trading costs, higher costs of
capital, and greater market volatility
should be mitigated.
Based on the many detailed
comments provided, the Agencies have
made substantive refinements to the
market-making exemption that the
Agencies believe will reduce the
likelihood that the rule, as
implemented, will negatively impact the
ability of banking entities to engage in
the types of market making-related
activities permitted under the statute
and, therefore, will continue to promote
(Feb. 14, 2012); FEI; ICI (Feb. 2012); TMA Hong
Kong; Sen. Casey.
613 See, e.g., Sens. Merkley & Levin (Feb. 2012);
Prof. Richardson; Better Markets (Feb. 2012); Profs.
Stout & Hastings; Prof. Johnson; Occupy; Public
Citizen; Profs. Admati & Pfleiderer; Better Markets
(June 2012).
614 See, e.g., Prof. Johnson.
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the benefits to investors and other
market participants described above,
including greater market liquidity,
narrower bid-ask spreads, reduced price
concessions and price impact, lower
volatility, and reduced counterparty
search costs, thus reducing the cost of
capital. For instance, the final marketmaking exemption does not require a
trade-by-trade analysis, which was a
significant source of concern from
commenters who represented, among
other things, that a trade-by-trade
analysis could have a chilling effect on
individual traders’ willingness to engage
in market-making activities.615 Rather,
the final rule has been crafted around
the overall market making-related
activities of individual trading desks,
with various requirements that these
activities be demonstrably related to
satisfying reasonably expected near term
customer demands and other marketmaking activities. The Agencies believe
that applying certain requirements to
the aggregate risk exposure of a trading
desk, along with the requirement to
establish risk and inventory limits to
routinize a trading desk’s compliance
with the near term customer demand
requirement, will reduce negative
potential impacts on individual traders’
decision-making process in the normal
course of market making.616 In addition,
in response to a large number of
comments expressing concern that the
proposed market-making exemption
would restrict or prohibit market
making-related activities in less liquid
markets, the Agencies are clarifying that
the application of certain requirements
in the final rule, such as the frequency
of required quoting and the near term
demand requirement, will account for
the liquidity, maturity, and depth of the
market for a given type of financial
instrument. Thus, banking entities will
be able to continue to engage in market
making-related activities across markets
and asset classes.
At the same time, the Agencies
recognize that an overly broad marketmaking exemption may allow banking
entities to mask speculative positions as
liquidity provision or related hedges.
The Agencies believe the requirements
included in the final rule are necessary
to prevent such evasion of the marketmaking exemption, ensure compliance
615 See supra note 517 (discussing commenters’
concerns regarding a trade-by-trade analysis).
616 For example, by clarifying that individual
trades will not be viewed in isolation and requiring
strong compliance procedures, this approach will
generally allow an individual trader to operate
within the compliance framework established for
his or her trading desk without having to assess
whether each individual transaction complies with
all requirements of the market-making exemption.
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with the statute, and facilitate internal
banking entity and external Agency
reviews of compliance with the final
rule. Nevertheless, the Agencies
acknowledge that these additional costs
may have an impact on banking entities’
willingness to engage in market makingrelated activities. Banking entities will
incur certain compliance costs in
connection with their market makingrelated activities under the final rule.
For example, banking entities may not
currently limit their trading desks’
market-maker inventory to that which is
designed not to exceed reasonably
expected near term customer demand,
as required by the statute.
As discussed above, commenters
presented diverging views on whether
non-banking entities are likely to enter
the market or increase their marketmaking activities if the final rule should
cause banking entities to reduce their
market-making activities.617 The
Agencies note that prior to the GrammLeach-Bliley Act of 1999, marketmaking services were more commonly
provided by non-bank-affiliated brokerdealers than by banking entities. As
discussed above, by intermediating and
facilitating trading, market makers
provide value to the markets and profit
from providing liquidity. Should
banking entities retreat from making
markets, the profit opportunities
available from providing liquidity will
provide an incentive for non-bankaffiliated broker-dealers to enter the
market and intermediate trades. The
Agencies are unable to assess the likely
effect with any certainty, but the
Agencies recognize that a marketmaking operation requires certain
infrastructure and capital, which will
impact the ability of non-banking
entities to enter the market-making
business or to increase their presence.
Therefore, should banking entities
retreat from making markets, there
could be a transition period with
reduced liquidity as non-banking
entities build up the needed
infrastructure and obtain capital.
However, because the Agencies have
substantially modified this exemption
in response to comments to ensure that
617 See supra notes 560 and 564 and
accompanying text (discussing comments on the
issue of whether non-banking entities are likely to
enter the market or increase their trading activities
in response to reduced trading activity by banking
entities). For example, one commenter stated that
broker-dealers that are not affiliated with a bank
would have reduced access to lender-of-last resort
liquidity from the central bank, which could limit
their ability to make markets during times of market
stress or when capital buffers are small. See Prof.
Duffie. However, another commenter noted that the
presence and evolution of market making after the
enactment of the Glass-Steagall Act mutes this
particular concern. See Prof. Richardson.
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market making related to near-term
customer demand is permitted as
contemplated by the statute, the
Agencies do not believe the final rule
should significantly impact currentlyavailable market-making services.618
c. Detailed Explanation of the MarketMaking Exemption
1. Requirement To Routinely Stand
Ready to Purchase and Sell
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a. Proposed Requirement To Hold Self
Out
Section ll.4(b)(2)(ii) of the
proposed rule would have required the
trading desk or other organizational unit
that conducts the purchase or sale in
reliance on the market-making
exemption to hold itself out as being
willing to buy and sell, including
through entering into long and short
positions in, the financial instrument for
its own account on a regular or
continuous basis.619 The proposal stated
that a banking entity could rely on the
proposed exemption only for the type of
financial instrument that the entity
actually made a market in.620
The proposal recognized that the
precise nature of a market maker’s
activities often varies depending on the
liquidity, trade size, market
infrastructure, trading volumes and
frequency, and geographic location of
the market for any particular financial
instrument.621 To account for these
variations, the Agencies proposed
indicia for assessing compliance with
this requirement that differed between
relatively liquid markets and less liquid
618 Certain non-banking entities, such as some
SEC-registered broker-dealers that are not banking
entities subject to the final rule, currently engage in
market-making activities and, thus, should have the
needed infrastructure and may attract additional
capital. If the final rule has a marginal impact on
banking entities’ willingness to engage in market
making-related activities, these non-banking entities
should be able to respond by increasing their
market making-related activities. The Agencies
recognize, however, that firms that do not have
existing infrastructure or sufficient capital are
unlikely to be able to act as market makers shortly
after the final rule is implemented. Nevertheless,
because some non-bank-affiliated broker-dealers
currently operate market-making desks, and
because it was the dominant model prior to the
Gramm-Leach-Bliley Act, the Agencies believe that
non-bank-affiliated financial intermediaries will be
able to provide market-making services longer term.
619 See proposed rule § ll.4(b)(2)(ii).
620 See Joint Proposal, 76 FR 68,870 (‘‘Notably,
this criterion requires that a banking entity relying
on the exemption with respect to a particular
transaction must actually make a market in the
[financial instrument] involved; simply because a
banking entity makes a market in one type of
[financial instrument] does not permit it to rely on
the market-making exemption for another type of
[financial instrument].’’); CFTC Proposal, 77 FR
8355–8356.
621 See Joint Proposal, 76 FR 68,870; CFTC
Proposal, 77 FR 8356.
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markets. Further, the Agencies
recognized that the proposed indicia
could not be applied at all times and
under all circumstances because some
may be inapplicable to the specific asset
class or market in which the market
making-related activity is conducted.
In particular, the proposal stated that
a trading desk or other organizational
unit’s market making-related activities
in relatively liquid markets, such as
equity securities or other exchangetraded instruments, should generally
include: (i) Making continuous, twosided quotes and holding oneself out as
willing to buy and sell on a continuous
basis; (ii) a pattern of trading that
includes both purchases and sales in
roughly comparable amounts to provide
liquidity; (iii) making continuous
quotations that are at or near the market
on both sides; and (iv) providing widely
accessible and broadly disseminated
quotes.622 With respect to market
making in less liquid markets, the
proposal noted that the appropriate
indicia of market making-related
activities will vary, but should generally
include: (i) holding oneself out as
willing and available to provide
liquidity by providing quotes on a
regular (but not necessarily continuous)
basis; 623 (ii) with respect to securities,
regularly purchasing securities from, or
selling securities to, clients, customers,
or counterparties in the secondary
market; and (iii) transaction volumes
and risk proportionate to historical
customer liquidity and investments
needs.624
In discussing this proposed
requirement, the Agencies stated that
bona fide market making-related activity
may include certain block positioning
and anticipatory position-taking. More
specifically, the proposal indicated that
the bona fide market making-related
activity described in § ll.4(b)(2)(ii) of
the proposed rule would include: (i)
block positioning if undertaken by a
trading desk or other organizational unit
of a banking entity for the purpose of
622 See Joint Proposal, 76 FR 68,870–68,871;
CFTC Proposal, 77 FR 8356. These proposed factors
are generally consistent with the indicia used by the
SEC to assess whether a broker-dealer is engaged in
bona fide market making for purposes of Regulation
SHO under the Exchange Act. See Joint Proposal,
76 FR 68,871 n.148; CFTC Proposal, 77 FR 8356
n.155.
623 The Agencies noted that, with respect to this
factor, the frequency of regular quotations will vary,
as moderately illiquid markets may involve
quotations on a daily or more frequent basis, while
highly illiquid markets may trade only by
appointment. See Joint Proposal, 76 FR 68,871
n.149; CFTC Proposal, 77 FR 8356 n.156.
624 See Joint Proposal, 76 FR 68,871; CFTC
Proposal, 77 FR 8356.
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5585
intermediating customer trading; 625 and
(ii) taking positions in securities in
anticipation of customer demand, so
long as any anticipatory buying or
selling activity is reasonable and related
to clear, demonstrable trading interest of
clients, customers, or counterparties.626
b. Comments on the Proposed
Requirement To Hold Self Out
Commenters raised many issues
regarding § ll.4(b)(2)(ii) of the
proposed exemption, which would
require a trading desk or other
organizational unit to hold itself out as
willing to buy and sell the financial
instrument for its own account on a
regular or continuous basis. As
discussed below, some commenters
viewed the proposed requirement as too
restrictive, while other commenters
stated that the requirement was too
permissive. Two commenters expressed
support for the proposed
requirement.627 A number of
commenters provided views on
statements in the proposal regarding
indicia of bona fide market making in
more and less liquid markets and the
permissibility of block positioning and
anticipatory position-taking.
Several commenters represented that
the proposed requirement was too
restrictive.628 For example, a number of
these commenters expressed concern
that the proposed requirement may limit
a banking entity’s ability to act as a
market maker under certain
circumstances, including in less liquid
markets, for instruments lacking a twosided market, or in customer-driven,
structured transactions.629 In addition, a
few commenters expressed specific
concern about how this requirement
would impact more limited marketmaking activity conducted by banks.630
625 In the preamble to the proposed rule, the
Agencies stated that the SEC’s definition of
‘‘qualified block positioner’’ may serve as guidance
in determining whether a block positioner engaged
in block positioning is engaged in bona fide market
making for purposes of § ll.4(b)(2)(ii) of the
proposed rule. See Joint Proposal, 76 FR 68,871
n.151; CFTC Proposal, 77 FR 8356 n.157.
626 See Joint Proposal, 76 FR 68,871; CFTC
Proposal, 77 FR 8356–8357.
627 See Sens. Merkley & Levin (Feb. 2012); Alfred
Brock.
628 See infra Part IV.A.3.c.1.c.iii. (addressing
these concerns).
629 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Morgan Stanley; Barclays; Goldman (Prop.
Trading); ABA; Chamber (Feb. 2012); BDA (Feb.
2012); Fixed Income Forum/Credit Roundtable;
ACLI (Feb. 2012); T. Rowe Price; PUC Texas; PNC;
MetLife; RBC; IHS; SSgA (Feb. 2012).
630 See, e.g., PNC (stating that the proposed rule
needs to account for market making by regional
banks on behalf of small and middle-market
customers whose securities are less liquid); ABA
(stating that the rule should continue to permit
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Many commenters indicated that it
was unclear whether this provision
would require a trading desk or other
organizational unit to regularly or
continuously quote every financial
instrument in which a market is made,
but expressed concern that the proposed
language could be interpreted in this
manner.631 These commenters noted
that there are thousands of individual
instruments within a given asset class,
such as corporate bonds, and that it
would be burdensome for a market
maker to provide quotes in such a large
number of instruments on a regular or
continuous basis.632 One of these
commenters represented that, because
customer demand may be infrequent in
a particular instrument, requiring a
banking entity to provide regular or
continuous quotes in the instrument
may not provide a benefit to its
customers.633 A few commenters
requested that the Agencies provide
further guidance on this issue or modify
the proposed standard to state that
holding oneself out in a range of similar
instruments will be considered to be
within the scope of permitted market
making-related activities.634
banks to provide limited liquidity by buying
securities that they feel are suitable for their retail
and institutional customer base by stating that a
bank is ‘‘holding itself out’’ when it buys and sells
securities that are suitable for its customers).
631 This issue is further discussed in Part
IV.A.3.c.1.c.iii., infra.
632 See, e.g., Goldman (Prop. Trading) (stating that
it would be burdensome for a U.S. credit marketmaking business to be required to produce and
disseminate quotes for thousands of individual
bond CUSIPs that trade infrequently and noting that
a market maker in credit markets will typically
disseminate indicative prices for the most liquid
instruments but, for the thousands of other
instruments that trade infrequently, the market
maker will generally provide a price for a trade
upon request from another market participant);
Morgan Stanley; SIFMA et al. (Prop. Trading) (Feb.
2012); RBC. See also BDA (Feb. 2012); FTN (stating
that in some markets, such as the markets for
residential mortgage-backed securities and
investment grade corporate debt, a market maker
will hold itself out in a subset of instruments (e.g.,
particular issues in the investment grade corporate
debt market with heavy trading volume or that are
in the midst of particular credit developments), but
will trade in other instruments within the group or
sector upon inquiry from customers and other
dealers); Oliver Wyman (Feb. 2012) (discussing data
regarding the number of U.S. corporate bonds and
frequency of trading in such bonds in 2009).
633 See Goldman (Prop. Trading).
634 See, e.g., RBC (recommending that the
Agencies clarify that a trading desk is required to
hold itself out as willing to buy and sell a particular
type of ‘‘product’’); SIFMA et al. (Prop. Trading)
(Feb. 2012) (suggesting that the Agencies use the
term ‘‘instrument,’’ rather than ‘‘covered financial
position,’’ to provide greater clarity); CIEBA
(supporting alternative criteria that would require a
banking entity to hold itself out generally as a
market maker for the relevant asset class, but not
for every instrument it purchases and sells);
Goldman (Prop. Trading). One of these commenters
recommended that the Agencies recognize and
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To address concerns about the
restrictiveness of this requirement,
commenters suggested certain
modifications. For example, some
commenters suggested adding language
to the requirement to account for market
making in markets that do not typically
involve regular or continuous, or twosided, quoting.635 In addition, a few
commenters requested that the
requirement expressly include
transactions in new instruments or
transactions in instruments that occur
infrequently to address situations where
a banking entity may not have
previously had the opportunity to hold
itself out as willing to buy and sell the
applicable instrument.636 Other
commenters supported alternative
criteria for assessing whether a banking
entity is acting as a market maker, such
as: (i) a willingness to respond to
customer demand by providing prices
upon request; 637 (ii) being in the
business of providing prices upon
request for that financial instrument or
other financial instruments in the same
permit the following kinds of activity in related
financial instruments: (i) Options market makers
should be deemed to be engaged in market making
in all put and call series related to a particular
underlying security and should be permitted to
trade the underlying security regardless of whether
such trade qualifies for the hedging exemption; (ii)
convertible bond traders should be permitted to
trade in the associated equity security; (iii) a market
maker in one issuer’s bonds should be considered
a market maker in similar bonds of other issuers;
and (iv) a market maker in standardized interest
rate swaps should be considered to be engaged in
market making-related activity if it engages in a
customized interest rate swap with a customer upon
request. See RBC.
635 See, e.g., Morgan Stanley (suggesting that the
Agencies add the phrase ‘‘or, in markets where
regular or continuous quotes are not typically
provided, the trading unit stands ready to provide
quotes upon request’’); Barclays (suggesting
addition of the phrase ‘‘to the extent that two-sided
markets are typically made by market makers in a
given product,’’ as well as changing the reference
to ‘‘purchase or sale’’ to ‘‘market making-related
activity’’ to avoid any inference of a trade-by-trade
analysis). See also Fixed Income Forum/Credit
Roundtable. To address concerns about the
requirement’s application to bespoke products, one
commenter suggested that the rule clearly state that
a banking entity fulfills this requirement if it
markets structured transactions to its client base
and stands ready to enter into such transactions
with customers, even though transactions may
occur on a relatively infrequent basis. See JPMC.
636 See Wells Fargo (Prop. Trading); RBC
(supporting this approach as an alternative to
removing the requirement from the rule, but
primarily supporting its removal). See also ISDA
(Feb. 2012) (stating that the analysis of compliance
with the proposed requirement must carefully
consider the degree of presence a market maker
wishes to have in a given market, which may
include being a leader in certain types of
instruments, having a secondary presence in others,
and potentially leaving or entering other
submarkets).
637 See SIFMA et al. (Prop. Trading) (Feb. 2012).
This commenter also suggested that such test be
assessed at the ‘‘trading unit’’ level. See id.
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or similar asset class or product
class; 638 or (iii) a historical test of
market-making activity, with
compliance judged on the basis of actual
trades.639 Finally, two commenters
stated that this requirement should be
moved to Appendix B of the rule,640
which, according to one of these
commenters, would provide the
Agencies greater flexibility to consider
the facts and circumstances of a
particular activity.641
Other commenters took the view that
the proposed requirement was too
permissive.642 For example, one
commenter stated that the proposed
standard provided too much room for
interpretation and would be difficult to
measure and monitor. This commenter
expressed particular concern that a
trading desk or other organizational unit
could meet this requirement by
regularly or continuously making wide,
out of context quotes that do not present
any real risk of execution and do not
contribute to market liquidity.643 Some
commenters suggested the Agencies
place greater restrictions on a banking
entity’s ability to rely on the marketmaking exemption in certain illiquid
markets, such as assets that cannot be
reliably valued, products that do not
have a genuine external market, or
instruments for which a banking entity
does not expect to have customers
wishing to both buy and sell.644 In
support of these requests, commenters
stated that trading in illiquid products
raises certain concerns under the rule,
including: a lack of reliable data for
purposes of using metrics to monitor a
banking entity’s market making-related
activity (e.g., products whose valuations
are determined by an internal model
that can be manipulated, rather than an
observable market price); 645 relation to
the last financial crisis; 646 lack of
important benefits to the real
economy; 647 similarity to prohibited
proprietary trading; 648 and
inconsistency with the statute’s
requirements that market makingrelated activity must be ‘‘designed not to
exceed the reasonably expected near
638 See
Goldman (Prop. Trading).
FTN.
640 See Flynn & Fusselman; JPMorgan.
641 See JPMC.
642 See, e.g., Occupy; AFR et al. (Feb. 2012);
Public Citizen; Johnson & Prof. Stiglitz; John Reed.
See infra note 746 and accompanying text
(responding to these comments).
643 See Occupy.
644 See Occupy; AFR et al. (Feb. 2012); Public
Citizen; Johnson & Prof. Stiglitz; Sens. Merkley &
Levin (Feb. 2012); John Reed.
645 See AFR et al. (Feb. 2012); Occupy.
646 See Occupy.
647 See John Reed.
648 See Johnson & Prof. Stiglitz.
639 See
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term demands of clients, customers, or
counterparties’’ and must not result in
a material exposure to high-risk assets
or high-risk trading strategies.649
These commenters also requested that
the proposed requirement be modified
in certain ways. In particular, several
commenters stated that the proposed
exemption should only permit market
making in assets that can be reliably
valued through external market
transactions.650 In order to implement
such a limitation, three commenters
suggested that the Agencies prohibit
banking entities from market making in
assets classified as Level 3 under FAS
157.651 One of these commenters
explained that Level 3 assets are
generally highly illiquid assets whose
fair value cannot be determined using
either market prices or models.652 In
addition, a few commenters suggested
that banking entities be subject to
additional capital charges for market
making in illiquid products.653 Another
commenter stated that the Agencies
should require all market makingrelated activity to be conducted on a
multilateral organized electronic trading
platform or exchange to make it possible
to monitor and confirm certain trading
649 See Sens. Merkley & Levin (Feb. 2012) (stating
that a banking entity must have or reasonably
expect at least two customers—one for each side of
the trade—and must have a reasonable expectation
of the second customer coming to take the position
or risk off its books in the ‘‘near term’’); AFR et al.
(Feb. 2012); Public Citizen.
650 See AFR et al. (Feb. 2012) (stating that the rule
should ban market making in illiquid and opaque
securities with no genuine external market, but
permit market making in somewhat illiquid
securities, such as certain corporate bonds, as long
as the securities can be reliably valued with
reference to other extremely similar securities that
are regularly traded in liquid markets and the
financial outcome of the transaction is reasonably
predictable); Johnson & Prof. Stiglitz
(recommending that permitted market making be
limited to assets that can be reliably valued in, at
a minimum, a moderately liquid market evidenced
by trading within a reasonable period, such as a
week, through a real transaction and not simply
with interdealer trades); Public Citizen (stating that
market making should be limited to assets that can
be reliably valued in a market where transactions
take place on a weekly basis).
651 See AFR et al. (Feb. 2012) (stating that such
a limitation would be consistent with the proposed
limitation on ‘‘high-risk assets’’ and the discussion
of this limitation in proposed Appendix C); Public
Citizen; Prof. Richardson.
652 See Prof. Richardson.
653 Two commenters recommended that banking
entities be required to treat trading in assets that
cannot be reliably valued and that trade only by
appointment, such as bespoke derivatives and
structured products, as providing an illiquid
bespoke loan, which are subject to higher capital
charges under the Federal banking agencies’ capital
rules. See Johnson & Prof. Stiglitz; John Reed.
Another commenter suggested that, if not directly
prohibited, trading in bespoke instruments that
cannot be reliably valued should be assessed an
appropriate capital charge. See Public Citizen.
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data.654 Two commenters emphasized
that their recommended restrictions on
market making in illiquid markets
should not prohibit banking entities
from making markets in corporate
bonds.655
i. The Proposed Indicia
As noted above, the proposal set forth
certain indicia of bona fide market
making-related activity in liquid and
less liquid markets that the Agencies
proposed to apply when evaluating
whether a banking entity was eligible
for the proposed exemption.656 Several
commenters provided their views
regarding the effectiveness of the
proposed indicia.
With respect to the proposed indicia
for liquid markets, a few commenters
expressed support for the proposed
indicia.657 One of these commenters
stated that while the proposed factors
are reasonably consistent with bona fide
market making, the Agencies should
add two other factors: (i) A willingness
to transact in reasonable quantities at
quoted prices, and (ii) inventory
turnover.658
Other commenters, however, stated
that the proposed use of factors from the
SEC’s analysis of bona fide market
making under Regulation SHO was
inappropriate in this context. In
particular, these commenters
represented that bona fide market
making for purposes of Regulation SHO
is a purposefully narrow concept that
permits a subset of market makers to
qualify for an exception from the
‘‘locate’’ requirement in Rule 203 of
Regulation SHO. The commenters
further expressed the belief that the
policy goals of section 13 of the BHC
Act do not necessitate a similarly
narrow interpretation of market
making.659
654 See Occupy. This commenter further
suggested that the exemption exclude all activities
that include: (i) Assets whose changes in value
cannot be mitigated by effective hedges; (ii) new
products with rapid growth, including those that do
not have a market history; (iii) assets or strategies
that include significant imbedded leverage; (iv)
assets or strategies that have demonstrated
significant historical volatility; (v) assets or
strategies for which the application of capital and
liquidity standards would not adequately account
for the risk; and (vi) assets or strategies that result
in large and significant concentrations to sectors,
risk factors, or counterparties. See id.
655 See AFR et al. (Feb. 2012); Johnson & Prof.
Stiglitz.
656 See supra Part IV.A.3.c.1.a.
657 See Occupy; AFR et al. (Feb. 2012); NYSE
Euronext (expressing support for the indicia set
forth in the FSOC study, which are substantially the
same as the indicia in the proposal); Alfred Brock.
658 See AFR et al. (Feb. 2012).
659 See Goldman (Prop. Trading); SIFMA et al.
(Prop. Trading) (Feb. 2012).
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A few commenters expressed
particular concern about how the factor
regarding patterns of purchases and
sales in roughly comparable amounts
would apply to market making in
exchange-traded funds (‘‘ETFs’’).
According to these commenters,
demonstrating this factor could be
difficult because ETF market making
involves a pattern of purchases and
sales of groups of equivalent securities
(i.e., the ETF shares and the basket of
securities and cash that is exchanged for
them), not a single security. In addition,
the commenters were unsure whether
this factor could be demonstrated in
times of limited trading in ETF
shares.660
The preamble to the proposed rule
also provided certain proposed indicia
of bona fide market making-related
activity in less liquid markets.661 As
discussed above, commenters had
differing views about whether the
exemption for market making-related
activity should permit banking entities
to engage in market making in some or
all illiquid markets. Thus, with respect
to the proposed indicia for market
making in less liquid markets,
commenters generally stated that the
indicia should be broader or narrower,
depending on the commenter’s overall
view on the issue of market making in
illiquid markets. One commenter stated
that the proposed indicia are
effective.662
The first proposed factor of market
making-related activity in less liquid
markets was holding oneself out as
willing and available to provide
liquidity by providing quotes on a
regular (but not necessarily continuous)
basis. As noted above, several
commenters expressed concern about a
requirement that market makers provide
regular quotations in less liquid
instruments, including in fixed income
markets and bespoke, customized
derivatives.663 With respect to the
interaction between the rule language
requiring ‘‘regular’’ quoting and the
proposal’s language permitting trading
by appointment under certain
circumstances, some of these
commenters expressed uncertainty
about how a market maker trading only
by appointment would be able to satisfy
the proposed rule’s regular quotation
660 See
ICI (Feb. 2012); ICI Global.
supra Part IV.A.3.c.1.a.
662 See Alfred Brock.
663 See supra note 629 accompanying text. With
respect to this factor, one commenter requested that
the Agencies delete the parenthetical of ‘‘but not
necessarily continuous’’ from the proposed factor as
part of a broader effort to recognize the relative
illiquidity of swap markets. See ISDA (Feb. 2012).
661 See
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requirement.664 In addition, another
commenter stated that the proposal’s
recognition of trading by appointment
does not alleviate concerns about
applying the ‘‘regular’’ quotation
requirement to market making in less
liquid instruments in markets that are
not, as a whole, highly illiquid, such as
credit and interest rate markets.665
Other commenters expressed concern
about only requiring a market maker to
provide regular quotations or permitting
trading by appointment to qualify for
the market-making exemption. With
respect to regular quotations, some
commenters stated that such a
requirement enables evasion of the
prohibition on proprietary trading
because a proprietary trader may post a
quote at a time of little interest in a
financial product or may post wide, out
of context quotes on a regular basis with
no real risk of execution.666 Several
commenters stated that trading only by
appointment should not qualify as
market making for purposes of the
proposed rule.667 Some of these
commenters stated that there is no
‘‘market’’ for assets that trade only by
appointment, such as customized,
structured products and OTC
derivatives.668
The second proposed criterion for
market making-related activity in less
liquid markets was, with respect to
securities, regularly purchasing
securities from, or selling securities to,
clients, customers, or counterparties in
the secondary market. Two commenters
expressed concern about this proposed
factor.669 In particular, one of these
commenters stated that the language is
fundamentally inconsistent with market
making because it contemplates that
only taking one side of the market is
sufficient, rather than both buying and
selling an instrument.670 The other
commenter expressed concern that
banking entities would be allowed to
accumulate a significant amount of
illiquid risk because the indicia for
market making-related activity in less
liquid markets did not require a market
maker to buy and sell in comparable
664 See SIFMA et al. (Prop. Trading) (Feb. 2012);
CIEBA. These commenters requested greater clarity
or guidance on the meaning of ‘‘regular’’ in the
instance of a market maker trading only by
appointment. See id.
665 See Goldman (Prop. Trading).
666 See Public Citizen; Occupy. One of these
commenters further noted that most markets lack a
structural framework that would enable monitoring
of compliance with this requirement. See Occupy.
667 See, e.g., Sens. Merkley & Levin (Feb. 2012);
Johnson & Prof. Stiglitz; John Reed; Public Citizen.
668 See, e.g., John Reed; Public Citizen.
669 See AFR et al. (Feb. 2012); Occupy.
670 See AFR et al. (Feb. 2012)
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amounts (as required by the indicia for
liquid markets).671
Finally, the third proposed factor of
market making in less liquid markets
would consider transaction volumes
and risk proportionate to historical
customer liquidity and investment
needs. A few commenters indicated that
there may not be sufficient information
available for a banking entity to conduct
such an analysis.672 For example, one
commenter stated that historical
information may not necessarily be
available for new businesses or
developing markets in which a market
maker may seek to establish trading
operations.673 Another commenter
expressed concern that this factor would
not help differentiate market making
from prohibited proprietary trading
because most illiquid markets do not
have a source for such historical risk
and volume data.674
ii. Treatment of Block Positioning
Activity
The proposal provided that the
activity described in § ll.4(b)(2)(ii) of
the proposed rule would include block
positioning if undertaken by a trading
desk or other organizational unit of a
banking entity for the purpose of
intermediating customer trading.675
A number of commenters supported
the general language in the proposal
permitting block positioning, but
expressed concern about the reference
to the definition of ‘‘qualified block
positioner’’ in SEC Rule 3b–8(c).676
With respect to using Rule 3b–8(c) as
guidance under the proposed rule, these
commenters represented that Rule 3b–
8(c)’s requirement to resell block
positions ‘‘as rapidly as possible’’ would
cause negative results (e.g., fire sales) or
create market uncertainty (e.g., when, if
ever, a longer unwind would be
permitted).677 According to one of these
commenters, gradually disposing of a
large long position purchased from a
customer may be the best means of
reducing near term price volatility
associated with the supply shock of
671 See
Occupy.
SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Occupy.
673 See Goldman (Prop. Trading).
674 See Occupy.
675 See Joint Proposal, 76 FR 68,871.
676 See, e.g., RBC; SIFMA (Asset Mgmt.) (Feb.
2012); Goldman (Prop. Trading). See also infra note
735 (responding to these comments).
677 See RBC (expressing concern about fire sales);
SIFMA (Asset Mgmt.) (Feb. 2012) (expressing
concern about fire sales, particularly in less liquid
markets where a block position would overwhelm
the market and undercut the price a market maker
can obtain); Goldman (Prop. Trading) (representing
that this requirement could create uncertainty about
whether a longer unwind would be permissible
and, if so, under what circumstances).
672 See
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trying to sell the position at once.678
Another commenter expressed concern
about the second requirement of Rule
3b–8(c), which provides that the dealer
must determine in the exercise of
reasonable diligence that the block
cannot be sold to or purchased from
others on equivalent or better terms.
This commenter stated that this kind of
determination would be difficult in less
liquid markets because those markets do
not have widely disseminated quotes
that dealers can use for purposes of
comparison.679
Beyond the reference to Rule 3b–8(c),
a few commenters expressed more
general concern about the proposed
rule’s application to block positioning
activity.680 One commenter noted that
the proposal only discussed block
positioning in the context of the
proposed requirement to hold oneself
out, which implies that block
positioning activity also must meet the
other requirements of the marketmaking exemption. This commenter
requested an explicit recognition that
banking entities meet the requirements
of the market-making exemption when
they enter into block trades for
customers, including related trades
entered to support the block, such as
hedging transactions.681 Finally, one
commenter expressed concern that the
inventory metrics in proposed
Appendix A would make dealers
reluctant to execute large, principal
transactions because such trades would
have a transparent impact on inventory
metrics in the relevant asset class.682
iii. Treatment of Anticipatory Market
Making
In the proposal, the Agencies
proposed that ‘‘bona fide market
making-related activity may include
taking positions in securities in
678 See
Goldman (Prop. Trading).
RBC.
680 See SIFMA (Asset Mgmt.) (Feb. 2012); Fidelity
(requesting that the Agencies explicitly recognize
that block trades qualify for the market-making
exemption); Oliver Wyman (Feb. 2012).
681 See SIFMA (Asset Mgmt.) (Feb. 2012).
682 See Oliver Wyman (Feb. 2012). This
commenter estimated that investors trading out of
large block positions on their own, without a
market maker directly providing liquidity, would
have to pay incremental transaction costs between
$1.7 and $3.4 billion per year. This commenter
estimated a block trading size of $850 billion, based
on a haircut of total block trading volume reported
for NYSE and Nasdaq. The commenter then
estimated, based on market interviews and analysis
of standard market impact models provided by
dealers, that the market impact of executing large
block orders without direct market maker liquidity
provision would be the difference between the
market impact costs of executing a block trade over
a 5-day period versus a 1-day period—which would
be approximately 20 to 50 basis points, depending
on the size of the trade. See id.
679 See
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anticipation of customer demand, so
long as any anticipatory buying or
selling activity is reasonable and related
to clear, demonstrable trading interest of
clients, customers, or
counterparties.’’ 683 Many commenters
indicated that the language in the
proposal is inconsistent with the
statute’s language regarding near term
demands of clients, customers, or
counterparties. According to these
commenters, the statute’s ‘‘designed’’
and ‘‘reasonably expected’’ language
expressly acknowledges that a market
maker may need to accumulate
inventory before customer demand
manifests itself. Commenters further
represented that the proposed standard
may unduly limit a banking entity’s
ability to accumulate inventory in
anticipation of customer demand.684
In addition, two commenters
expressed concern that the proposal’s
language would effectively require a
banking entity to engage in
impermissible front running.685 One of
these commenters indicated that the
Agencies should not restrict
anticipatory trading to such a short time
period.686 To the contrary, the other
commenter stated that anticipatory
accumulation of inventory should be
considered to be prohibited proprietary
trading.687 A few commenters noted that
the standard in the proposal explicitly
refers to securities and requested that
the reference be changed to encompass
the full scope of financial instruments
covered by the rule to avoid
ambiguity.688 Several commenters
recommended that the language be
683 Joint Proposal, 76 FR 68,871; CFTC Proposal,
77 FR 8356–8357.
684 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (expressing concern that requiring trades to
be related to clear demonstrable trading interest
could curtail the market-making function by
removing a market maker’s discretion to develop
inventory to best serve its customers and adversely
restrict liquidity); Goldman (Prop. Trading);
Chamber (Feb. 2012); Comm. on Capital Markets
Regulation. See also Morgan Stanley (requesting
certain revisions to more closely track the statute);
SIFMA (Asset Mgmt.) (Feb. 2012) (expressing
general concern that the standard creates
limitations on a market maker’s inventory). These
comments are addressed in Part IV.A.3.c.2., infra.
685 See Goldman (Prop. Trading); Occupy. See
also Public Citizen (expressing general concern that
accumulating positions in anticipation of demand
opens issues of front running).
686 See Goldman (Prop. Trading).
687 See Occupy.
688 See Goldman (Prop. Trading); ISDA (Feb.
2012); SIFMA et al. (Prop. Trading) (Feb. 2012).
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eliminated 689 or modified 690 to address
the concerns discussed above.
iv. High-Frequency Trading
A few commenters stated that highfrequency trading should be considered
prohibited proprietary trading under the
rule, not permitted market makingrelated activity.691 For example, one
commenter stated that the Agencies
should not confuse high volume trading
and market making. This commenter
emphasized that algorithmic traders in
general—and high-frequency traders in
particular—do not hold themselves out
in the manner required by the proposed
rule, but instead only offer to buy and
sell when they think it is profitable.692
Another commenter suggested the
Agencies impose a resting period on any
order placed by a banking entity in
reliance on any exemption in the rule
by, for example, prohibiting a banking
entity from buying and subsequently
selling a position within a span of two
seconds.693
c. Final Requirement To Routinely
Stand Ready To Purchase And Sell
Section ll.4(b)(2)(i) of the final rule
provides that the trading desk that
establishes and manages the financial
exposure must routinely stand ready to
purchase and sell one or more types of
financial instruments related to its
financial exposure and be willing and
available to quote, buy and sell, or
otherwise enter into long and short
positions in those types of financial
689 See BoA (stating that a market maker must
acquire inventory in advance of express customer
demand and customers expect a market maker’s
inventory to include not only the financial
instruments in which customers have previously
traded, but also instruments that the banking entity
believes they may want to trade); Occupy.
690 See Morgan Stanley (suggesting a new
standard providing that a purchase or sale must be
‘‘reasonably consistent with observable customer
demand patterns and, in the case of new asset
classes or markets, with reasonably expected future
developments on the basis of the trading unit’s
client relationships’’); Chamber (Feb. 2012)
(requesting that the final rule permit market makers
to make individualized assessments of anticipated
customer demand based on their expertise and
experience in the markets and make trades
according to those assessments); Goldman (Prop.
Trading) (recommending that the Agencies instead
focus on how trading activities are ‘‘designed’’ to
meet the reasonably expected near term demands of
clients over time, rather than whether those
demands have actually manifested themselves at a
given point in time); ISDA (Feb. 2012) (stating that
the Agencies should clarify this language to
recognize differences between liquid and illiquid
markets and noting that illiquid and low volume
markets necessitate that swap dealers take a longer
and broader view than dealers in liquid markets).
691 See, e.g., Better Markets (Feb. 2012); Occupy;
Public Citizen.
692 See Better Markets (Feb. 2012). See also infra
note 742 (addressing this issue).
693 See Occupy.
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instruments for its own account, in
commercially reasonable amounts and
throughout market cycles, on a basis
appropriate for the liquidity, maturity,
and depth of the market for the relevant
types of financial instruments. As
discussed in more detail below, the
standard of ‘‘routinely’’ standing ready
to purchase and sell one or more types
of financial instruments will be
interpreted to account for differences
across markets and asset classes. In
addition, this requirement provides that
a trading desk must be willing and
available to provide quotations and
transact in the particular types of
financial instruments in commercially
reasonable amounts and throughout
market cycles. Thus, a trading desk’s
activities would not meet the terms of
the market-making exemption if, for
example, the trading desk only provides
wide quotations on one or both sides of
the market relative to prevailing market
conditions or is only willing to trade on
an irregular, intermittent basis.
While this provision of the marketmaking exemption has some similarity
to the requirement to hold oneself out
in § ll.4(b)(2)(ii) of the proposed rule,
the Agencies have made a number of
refinements in response to comments.
Specifically, a number of commenters
expressed concern that the proposed
requirement did not sufficiently account
for differences between markets and
asset classes and would unduly limit
certain types of market making by
requiring ‘‘regular or continuous’’
quoting in a particular instrument.694
The explanation of this requirement in
the proposal was intended to address
many of these concerns. For example,
the Agencies stated that the proposed
‘‘indicia cannot be applied at all times
and under all circumstances because
some may be inapplicable to the specific
asset class or market in which the
market-making activity is
conducted.’’ 695 Nonetheless, the
Agencies believe that certain
modifications are warranted to clarify
the rule and to prevent a potential
chilling effect on market making-related
activities conducted by banking entities.
Commenters represented that the
requirement that a trading desk hold
itself out as being willing to buy and sell
‘‘on a regular or continuous basis,’’ as
was originally proposed, was impossible
694 See supra Part IV.A.3.c.1.b. (discussing
comments on this issue). The Agencies did not
intend for the reference to ‘‘covered financial
position’’ in the proposed rule to imply a single
instrument, although commenters contended that
the proposal may not have been sufficiently clear
on this point.
695 Joint Proposal, 76 FR 68,871; CFTC Proposal,
77 FR 8356.
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to meet or impractical in the context of
many markets, especially less liquid
markets.696 Accordingly, the final rule
requires a trading desk that establishes
and manages the financial exposure to
‘‘routinely’’ stand ready to trade one or
more types of financial instruments
related to its financial exposure. As
discussed below, the meaning of
‘‘routinely’’ will account for the
liquidity, maturity, and depth of the
market for a type of financial
instrument, which should address
commenter concern that the proposed
standard would not work in less liquid
markets and would have a chilling effect
on banking entities’ ability to act as
market makers in less liquid markets. A
concept of market making that is
applicable across securities, commodity
futures, and derivatives markets has not
previously been defined by any of the
Agencies. Thus, while this standard is
based generally on concepts from the
securities laws and is consistent with
the CFTC’s and SEC’s description of
market making in swaps,697 the
Agencies note that it is not directly
based on an existing definition of
market making.698 Instead, the approach
696 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Morgan Stanley; Barclays; Goldman (Prop.
Trading); ABA; Chamber (Feb. 2012); BDA (Feb.
2012); Fixed Income Forum/Credit Roundtable;
ACLI (Feb. 2012); T. Rowe Price; PUC Texas; PNC;
MetLife; RBC; SSgA (Feb. 2012). Some commenters
suggested alternative criteria, such as providing
prices upon request, using a historical test of market
making, or a purely guidance-based approach. See
SIFMA et al. (Prop. Trading) (Feb. 2012); Goldman
(Prop. Trading); FTN; Flynn & Fusselman; JPMC.
The Agencies are not adopting a requirement that
the trading desk only provide prices upon request
because the Agencies believe it would be
inconsistent with market making in liquid
exchange-traded instruments where market makers
regularly or continuously post quotes on an
exchange. With respect to one commenter’s
suggested approach of a historical test of market
making, this commenter did not provide enough
information about how such a test would work for
the Agencies’ consideration. Finally, the final rule
does not adopt a purely guidance-based approach
because, as discussed further above, the Agencies
believe it could lead to an increased risk of evasion.
697 See Further Definition of ‘‘Swap Dealer,’’
‘‘Security-Based Swap Dealer,’’ ‘‘Major Swap
Participant,’’ ‘‘Major Security-Based Swap
Participant’’ and ‘‘Eligible Contract Participant’’, 77
FR 30596, 30609 (May 23, 2012) (describing market
making in swaps as ‘‘routinely standing ready to
enter into swaps at the request or demand of a
counterparty’’).
698 As a result, activity that is considered market
making under this final rule may not necessarily be
considered market making for purposes of other
laws or regulations, such as the U.S. securities laws,
the rules and regulations thereunder, or selfregulatory organization rules. In addition, the
Agencies note that a banking entity acting as an
underwriter would continue to be treated as an
underwriter for purposes of the securities laws and
the regulations thereunder, including any liability
arising under the securities laws as a result of acting
in such capacity, regardless of whether it is able to
meet the terms of the market-making exemption for
its activities. See Sens. Merkley & Levin (Feb. 2012).
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taken in the final rule is intended to
take into account and accommodate the
conditions in the relevant market for the
financial instrument in which the
banking entity is making a market.
i. Definition of ‘‘Trading Desk’’
The Agencies are adopting a marketmaking exemption with requirements
that generally focus on a financial
exposure managed by a ‘‘trading desk’’
of a banking entity and such trading
desk’s market-maker inventory. The
market-making exemption as originally
proposed would have applied to ‘‘a
trading desk or other organizational
unit’’ of a banking entity. In addition,
for purposes of the proposed
requirement to report and record certain
quantitative measurements, the proposal
defined the term ‘‘trading unit’’ as each
of the following units of organization of
a banking entity: (i) Each discrete unit
that is engaged in the coordinated
implementation of a revenue-generation
strategy and that participates in the
execution of any covered trading
activity; (ii) each organizational unit
that is used to structure and control the
aggregate risk-taking activities and
employees of one or more trading units
described in paragraph (i); and (iii) all
trading operations, collectively.699
The Agencies received few comments
regarding the organizational level at
which the requirements of the marketmaking exemption should apply, and
many of the commenters that addressed
this issue did not describe their
suggested approach in detail.700 One
commenter suggested that the marketmaking exemption apply to each
‘‘trading unit’’ of a banking entity,
defined as ‘‘each organizational unit
that is used to structure and control the
aggregate risk-taking activities and
employees that are engaged in the
coordinated implementation of a
customer-facing revenue generation
strategy and that participate in the
execution of any covered trading
activity.’’ 701 This suggested approach is
substantially similar to the second
prong of the Agencies’ proposed
definition of ‘‘trading unit’’ in Appendix
A of the proposal. The Agencies
described this prong as generally
including management or reporting
divisions, groups, sub-groups, or other
intermediate units of organization used
by the banking entity to manage one or
more discrete trading units (e.g., ‘‘North
American Credit Trading,’’ ‘‘Global
699 See Joint Proposal, 76 FR 68,957; CFTC
Proposal, 77 FR 8436.
700 See Wellington; SIFMA et al. (Prop. Trading)
(Feb. 2012).
701 Morgan Stanley.
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Credit Trading,’’ etc.).702 The Agencies
are concerned that this commenter’s
suggested approach, or any other
approach applying the exemption’s
requirements to a higher level of
organization than the trading desk,
would impede monitoring of market
making-related activity and detection of
impermissible proprietary trading by
combining a number of different trading
strategies and aggregating a larger
volume of trading activities.703 Further,
key requirements in the market-making
exemption, such as the required limits
and risk management procedures, are
generally used by banking entities for
risk control and applied at the trading
desk level. Thus, applying them at a
broader organizational level than the
trading desk would create a separate
system for compliance with this
exemption designed to permit a banking
entity to aggregate disparate trading
activities and apply limits more
generally. Applying the conditions of
the exemption at a more aggregated
level would allow banking entities more
flexibility in trading and could result in
a higher volume of trading that could
contribute modestly to liquidity.704
Instead of taking that approach, the
Agencies have determined to permit a
broader range of market making-related
activities that can be effectively
controlled by building on risk controls
used by trading desks for business
purposes. This will allow an individual
trader to use instruments or strategies
within limits established in the
compliance program to confidently
trade in the type of financial
instruments in which his or her trading
desk makes a market. The Agencies
believe this addresses concerns that
uncertainty would negatively impact
liquidity. It also addresses concerns that
applying the market-making exemption
at a higher level of organization would
reduce the effectiveness of the
requirements in the final rule aimed at
ensuring that the quality and character
of trading is consistent with market
702 See
Joint Proposal, 76 FR 68,957 n.2.
e.g., Occupy (expressing concern that,
with respect to the proposed definition of ‘‘trading
unit,’’ an ‘‘oversized’’ unit could combine
significantly unrelated trading desks, which would
impede detection of proprietary trading activity).
704 The Agencies recognize that the proposed
rule’s application to a trading desk ‘‘or other
organizational unit’’ would have provided banking
entities with this type of flexibility to determine the
level of organization at which the market-making
exemption should apply based on the entity’s
particular business structure and trading strategies,
which would likely reduce the burdens of this
aspect of the final rule. However, for the reasons
noted above regarding application of this exemption
to a higher organizational level than the trading
desk, the Agencies are not adopting the ‘‘or other
organizational unit’’ language.
703 See,
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making-related activity and would
increase the risk of evasion. Moreover,
several provisions of the final rule are
intended to account for the liquidity,
maturity, and depth of the market for a
given type of financial instrument in
which the trading desk makes a market.
The final rule takes account of these
factors to, among other things, respond
to commenters’ concerns about the
proposed rule’s potential impact on
market making in less liquid markets.
Applying these requirements at an
organizational level above the trading
desk would be more likely to result in
aggregation of trading in various types
of instruments with differing levels of
liquidity, which would make it more
difficult for these market factors to be
taken into account for purposes of the
exemption (for example, these factors
are considered for purposes of tailoring
the analysis of reasonably expected near
term demands of customers and
establishing risk, inventory, and
duration limits).
Thus, the Agencies continue to
believe that certain requirements of the
exemption should apply to a relatively
granular level of organization within a
banking entity (or across two or more
affiliated banking entities). These
requirements of the final market-making
exemption have been formulated to best
reflect the nature of activities at the
trading desk level of granularity.
As explained below, the Agencies are
applying certain requirements to a
‘‘trading desk’’ of a banking entity and
adopting a definition of this term in the
final rule.705 The definition of ‘‘trading
desk’’ is similar to the first prong of the
proposed definition of ‘‘trading unit.’’
The Agencies are not adopting the
proposed ‘‘or other organizational unit’’
language because the Agencies are
concerned that approach would have
provided banking entities with too
much discretion to independently
determine the organizational level at
which the requirements should apply,
including a more aggregated level of
organization, which could lead to
evasion of the general prohibition on
proprietary trading and the other
concerns noted above. The Agencies
believe that adopting an approach
focused on the trading desk level will
allow banking entities and the Agencies
to better distinguish between permitted
market making-related activities and
trading that is prohibited by section 13
of the BHC Act and, thus, will prevent
evasion of the statutory requirements, as
discussed in more detail below. Further,
as discussed below, the Agencies
believe that applying requirements at
705 See
final rule § ll.3(e)(13).
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the trading desk level is balanced by the
financial exposure-based approach,
which will address commenters’
concerns about the burdens of trade-bytrade analyses.
In the final rule, trading desk is
defined to mean the smallest discrete
unit of organization of a banking entity
that buys or sells financial instruments
for the trading account of the banking
entity or an affiliate thereof. The
Agencies expect that a trading desk
would be managed and operated as an
individual unit and should reflect the
level at which the profit and loss of
market-making traders is attributed.706
The geographic location of individual
traders is not dispositive for purposes of
the analysis of whether the traders may
comprise a single trading desk. For
instance, a trading desk making markets
in U.S. investment grade telecom
corporate credits may use trading
personnel in both New York (to trade
U.S. dollar-denominated bonds issued
by U.S.-incorporated telecom
companies) and London (to trade Eurodenominated bonds issued by the same
type of companies). This approach
allows more effective management of
risks of trading activity by requiring the
establishment of limits, management
oversight, and accountability at the level
where trading activity actually occurs. It
also allows banking entities to tailor the
limits and procedures to the type of
instruments traded and markets served
by each trading desk.
In response to comments, and as
discussed below in the context of the
‘‘financial exposure’’ definition, a
trading desk may manage a financial
exposure that includes positions in
different affiliated legal entities.707
Similarly, a trading desk may include
employees working on behalf of
multiple affiliated legal entities or
booking trades in multiple affiliated
entities. Using the previous example,
the U.S. investment grade telecom
corporate credit trading desk may
include traders working for or booking
into a broker-dealer entity (for corporate
bond trades), a security-based swap
dealer entity (for single-name CDS
706 For example, the Agencies expect a banking
entity may determine the foreign exchange options
desk to be a trading desk; however, the Agencies
do not expect a banking entity to consider an
individual Japanese Yen options trader (i.e., the
trader in charge of all Yen-based options trades) as
a trading desk, unless the banking entity manages
its profit and loss, market making, and hedging in
Japanese Yen options independently of all other
financial instruments.
707 See infra note 724 and accompanying text.
Several commenters noted that market-making
activities may be conducted across separate
affiliated legal entities. See, e.g., SIFMA et al. (Prop.
Trading) (Feb. 2012); Goldman (Prop. Trading).
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5591
trades), and/or a swap dealer entity (for
index CDS or interest rate swap hedges).
To clarify this issue, the definition of
‘‘trading desk’’ specifically provides that
the desk can buy or sell financial
instruments ‘‘for the trading account of
a banking entity or an affiliate thereof.’’
Thus, a trading desk need not be
constrained to a single legal entity,
although it is permissible for a trading
desk to only trade for a single legal
entity. A trading desk booking positions
in different affiliated legal entities must
have records that identify all positions
included in the trading desk’s financial
exposure and where such positions are
held, as discussed below.708
The Agencies believe that establishing
a defined organizational level at which
many of the market-making exemption’s
requirements apply will address
potential evasion concerns. Applying
certain requirements of the marketmaking exemption at the trading desk
level will strengthen their effectiveness
and prevent evasion of the exemption
by ensuring that the aggregate trading
activities of a relatively limited group of
traders on a single desk are conducted
in a manner that is consistent with the
exemption’s standards. In particular,
because many of the requirements in the
market-making exemption look to the
specific type(s) of financial instruments
in which a market is being made, and
such requirements are designed to take
into account differences among markets
and asset classes, the Agencies believe
it is important that these requirements
be applied to a discrete and identifiable
unit engaged in, and operated by
personnel whose responsibilities relate
to, making a market in a specific set or
type of financial instruments. Further,
applying requirements at the trading
desk level should facilitate banking
entity monitoring and review of
compliance with the exemption by
limiting the aggregate trading volume
that must be reviewed, as well as
allowing consideration of the particular
facts and circumstances of the desk’s
trading activities (e.g., the liquidity,
maturity, and depth of the market for
the relevant types of financial
instruments). As discussed above, the
Agencies believe that applying the
requirements of the market-making
exemption to a higher level of
organization would reduce the ability to
consider the liquidity, maturity, and
depth of the market for a type of
financial instrument, would impede
effective monitoring and compliance
reviews, and would increase the risk of
evasion.
708 See
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ii. Definitions of ‘‘Financial Exposure’’
and ‘‘Market-Maker Inventory’’
Certain requirements of the proposed
market-making exemption referred to a
‘‘purchase or sale of a [financial
instrument].’’ 709 Even though the
Agencies did not intend to require a
trade-by-trade review, a significant
number of commenters expressed
concern that this language could be read
to require compliance with the
proposed market-making exemption on
a transaction-by-transaction basis.710 In
response to these concerns, the
Agencies are modifying the exemption
to clarify the manner in which
compliance with certain provisions will
be assessed. In particular, rather than a
transaction-by-transaction focus, the
market-making exemption in the final
rule focuses on two related aspects of
market-making activity: A trading desk’s
‘‘market-maker inventory’’ and its
overall ‘‘financial exposure.’’ 711
The Agencies are adopting an
approach that focuses on both a trading
desk’s financial exposure and marketmaker inventory in recognition that
market making-related activity is best
viewed in a holistic manner and that,
during a single day, a trading desk may
engage in a large number of purchases
and sales of financial instruments.
While all these transactions must be
conducted in compliance with the
market-making exemption, the Agencies
recognize that they involve financial
instruments for which the trading desk
acts as market maker (i.e., by standing
ready to purchase and sell that type of
financial instrument) and instruments
that are acquired to manage the risks of
positions in financial instruments for
which the desk acts as market maker,
but in which the desk is not itself a
market maker.712
The final rule requires that activity by
a trading desk under the market-making
proposed rule § ll.4(b).
commenters also contended that
language in proposed Appendix B raised
transaction-by-transaction implications. See supra
notes 517 to 524 and accompanying text (discussing
commenters’ transaction-by-transaction concerns).
711 The Agencies are not adopting a transactionby-transaction approach because the Agencies are
concerned that such an approach would be unduly
burdensome or impractical and inconsistent with
the manner in which bona fide market makingrelated activity is conducted. Additionally, the
Agencies are concerned that the burdens of such an
approach would cause banking entities to
significantly reduce or cease market making-related
activities, which would cause negative market
impacts harmful to both investors and issuers, as
well as the financial system generally.
712 See Joint Proposal, 76 FR 68,870 n.146 (‘‘The
Agencies note that a market maker may often make
a market in one type of [financial instrument] and
hedge its activities using different [financial
instruments] in which it does not make a market.’’);
CFTC Proposal, 77 FR 8356 n.152.
709 See
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710 Some
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exemption be evaluated by a banking
entity through monitoring and setting
limits for the trading desk’s marketmaker inventory and financial exposure.
The market-maker inventory of a trading
desk includes the positions in financial
instruments, including derivatives, in
which the trading desk acts as market
maker. The financial exposure of the
trading desk includes the aggregate risks
of financial instruments in the marketmaker inventory of the trading desk plus
the financial instruments, including
derivatives, that are acquired to manage
the risks of the positions in financial
instruments for which the trading desk
acts as a market maker, but in which the
trading desk does not itself make a
market, as well as any associated loans,
commodities, and foreign exchange that
are acquired as incident to acting as a
market maker. In addition, the trading
desk generally must maintain its
market-maker inventory and financial
exposure within its market-maker
inventory limit and its financial
exposure limit, respectively and, to the
extent that any limit of the trading desk
is exceeded, the trading desk must take
action to bring the trading desk into
compliance with the limits as promptly
as possible after the limit is
exceeded.713 Thus, if market movements
cause a trading desk’s financial
exposure to exceed one or more of its
risk limits, the trading desk must
promptly take action to reduce its
financial exposure or obtain approval
for an increase to its limits through the
required escalation procedures, detailed
below. A trading desk may not,
however, enter into a trade that would
cause it to exceed its limits without first
receiving approval through its
escalation procedures.714
Under the final rule, the term marketmaker inventory is defined to mean all
of the positions, in the financial
instruments for which the trading desk
stands ready to make a market in
accordance with paragraph (b)(2)(i) of
this section, that are managed by the
trading desk, including the trading
desk’s open positions or exposures
arising from open transactions.715 Those
financial instruments in which a trading
desk acts as market maker must be
identified in the trading desk’s
compliance program under § ll
.4(b)(2)(iii)(A) of the final rule. As used
throughout this SUPPLEMENTARY
INFORMATION, the term ‘‘inventory’’
refers to both the retention of financial
instruments (e.g., securities) and, in the
context of derivatives trading, the risk
final rule § ll.4(b)(2)(iv).
final rule § ll.4(b)(2)(iii)(E).
715 See final rule § ll.4(b)(5).
713 See
714 See
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exposures arising out of market-making
related activities.716 Consistent with the
statute, the final rule requires that the
market-maker inventory of a trading
desk be designed not to exceed, on an
ongoing basis, the reasonably expected
near term demands of clients,
customers, or counterparties.
The financial exposure concept is
broader in scope than market-maker
inventory and reflects the aggregate
risks of the financial instruments (as
well as any associated loans, spot
commodities, or spot foreign exchange
or currency) the trading desk manages
as part of its market making-related
activities.717 Thus, a trading desk’s
financial exposure will take into
account a trading desk’s positions in
instruments for which it does not act as
a market maker, but which are
established as part of its market makingrelated activities, which includes risk
mitigation and hedging. For instance, a
trading desk that acts as a market maker
in Euro-denominated corporate bonds
may, in addition to Euro-denominated
bonds, enter into credit default swap
transactions on individual European
corporate bond issuers or an index of
European corporate bond issuers in
order to hedge its exposure arising from
its corporate bond inventory, in
accordance with its documented
hedging policies and procedures.
Though only the corporate bonds would
be considered as part of the trading
desk’s market-maker inventory, its
overall financial exposure would also
include the credit default swaps used
for hedging purposes.
As noted above, the Agencies believe
the extent to which a trading desk is
engaged in permitted market makingrelated activities is best determined by
716 As noted in the proposal, certain types of
market making-related activities, such as market
making in derivatives, involves the retention of
principal exposures rather than the retention of
actual financial instruments. See Joint Proposal, 76
FR 68,869 n.143; CFTC Proposal, 77 FR 8354 n.149.
This type of activity would be included under the
concept of ‘‘inventory’’ in the final rule.
717 The Agencies recognize that under the statute
a banking entity’s positions in loans, spot
commodities, and spot foreign exchange or
currency are not subject to the final rule’s
restrictions on proprietary trading. Thus, a banking
entity’s trading in these instruments does not need
to comply with the market-making exemption or
any other exemption to the prohibition on
proprietary trading. A banking entity may, however,
include exposures in loans, spot commodities, and
spot foreign exchange or currency that are related
to the desk’s market-making activities in
determining the trading desk’s financial exposure
and in turn, the desk’ s financial exposure limits
under the market-making exemption. The Agencies
believe this will provide a more accurate picture of
the trading desk’s financial exposure. For example,
a market maker in foreign exchange forwards or
swaps may mitigate the risks of its market-maker
inventory with spot foreign exchange.
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evaluating both the financial exposure
that results from the desk’s trading
activity and the amount, types, and risks
of the financial instruments in the
desk’s market-maker inventory. Both
concepts are independently valuable
and will contribute to the effectiveness
of the market-making exemption.
Specifically, a trading desk’s financial
exposure will highlight the net exposure
and risks of its positions and, along with
an analysis of the actions the trading
desk will take to demonstrably reduce
or otherwise significantly mitigate
promptly the risks of that exposure
consistent with its limits, the extent to
which it is appropriately managing the
risk of its market-maker inventory
consistent with applicable limits, all of
which are significant to an analysis of
whether a trading desk is engaged in
market making-related activities. An
assessment of the amount, types, and
risks of the financial instruments in a
trading desk’s market-maker inventory
will identify the aggregate amount of the
desk’s inventory in financial
instruments for which it acts as market
maker, the types of these financial
instruments that the desk holds at a
particular time, and the risks arising
from such holdings. Importantly, an
analysis of a trading desk’s marketmaker inventory will inform the extent
to which this inventory is related to the
reasonably expected near term demands
of clients, customers, or counterparties.
Because the market-maker inventory
concept is more directly related to the
financial instruments that a trading desk
buys and sells from customers than the
financial exposure concept, the
Agencies believe that requiring review
and analysis of a trading desk’s marketmaker inventory, as well as its financial
exposure, will enhance compliance with
the statute’s near-term customer
demand requirement. While the
amount, types, and risks of a trading
desk’s market-maker inventory are
constrained by the near-term customer
demand requirement, any other
positions in financial instruments
managed by the trading desk as part of
its market making-related activities (i.e.,
those reflected in the trading desk’s
financial exposure, but not included in
the trading desk’s market-maker
inventory) are also constrained because
they must be consistent with the
market-maker inventory or, if taken for
hedging purposes, designed to reduce
the risks of the trading desk’s marketmaker inventory.
The Agencies note that disaggregating
the trading desk’s market-maker
inventory from its other exposures also
allows for better identification of the
trading desk’s hedging positions in
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instruments for which the trading desk
does not make a market. As a result, a
banking entity’s systems should be able
to readily identify and monitor the
trading desk’s hedging positions that are
not in its market-maker inventory. As
discussed in Part IV.A.3.c.3., a trading
desk must have certain inventory and
risk limits on its market-maker
inventory, the products, instruments,
and exposures the trading desk may use
for risk management purposes, and its
financial exposure that are designed to
facilitate the trading desk’s compliance
with the exemption and that are based
on the nature and amount of the trading
desk’s market making-related activities,
including analyses regarding the
reasonably expected near term demands
of customers.718
The final rule also requires these
policies and procedures to contain
escalation procedures if a trade would
exceed the limits set for the trading
desk. However, the final rule does not
permit a trading desk to exceed the
limits solely based on customer
demand. Rather, before executing a
trade that would exceed the desk’s
limits or changing the desk’s limits, a
trading desk must first follow the
relevant escalation procedures, which
may require additional approval within
the banking entity and provide
demonstrable analysis that the basis for
any temporary or permanent increase in
limits is consistent with the reasonably
expected near term demands of
customers.
Due to these considerations, the
Agencies believe the final rule should
result in more efficient compliance
analyses on the part of both banking
entities and Agency supervisors and
examiners and should be less costly for
banking entities to implement than a
transaction-by-transaction or
instrument-by-instrument approach. For
example, the Agencies believe that some
banking entities already compute and
monitor most trading desks’ financial
exposures for risk management or other
purposes.719 The Agencies also believe
that focusing on the financial exposure
and market-maker inventory of a trading
desk, as opposed to each separate
individual transaction, is consistent
with the statute’s goal of reducing
proprietary trading risk in the banking
system and its exemption for market
making-related activities. The Agencies
recognize that banking entities may not
currently disaggregate trading desks’
market-maker inventory from their
financial exposures and that, to the
extent banking entities do not currently
separately identify trading desks’
market-maker inventory, requiring such
disaggregation for purposes of this rule
will impose certain costs. In addition,
the Agencies understand that an
approach focused solely on the
aggregate of all the unit’s trading
positions, as suggested by some
commenters, would present fewer
burdens.720 However, for the reasons
discussed above, the Agencies believe
such disaggregation is necessary to give
full effect to the statute’s near term
customer demand requirement.
The Agencies note that whether a
financial instrument or exposure
stemming from a derivative is
considered to be market-maker
inventory is based only on whether the
desk makes a market in the financial
instrument, regardless of the type of
counterparty or the purpose of the
transaction. Thus, the Agencies believe
that banking entities should be able to
develop a standardized methodology for
identifying a trading desk’s positions
and exposures in the financial
instruments for which it acts as a market
maker. As further discussed in this Part,
a trading desk’s financial exposure must
reflect the aggregate risks managed by
the trading desk as part of its market
making-related activities,721 and a
banking entity should be able to
demonstrate that the financial exposure
of a trading desk is related to its marketmaking activities.
The final rule defines ‘‘financial
exposure’’ to mean the ‘‘aggregate risks
of one or more financial instruments
and any associated loans, commodities,
or foreign exchange or currency, held by
a banking entity or its affiliate and
managed by a particular trading desk as
part of the trading desk’s market
making-related activities.’’ 722 In this
context, the term ‘‘aggregate’’ does not
imply that a long exposure in one
instrument can be combined with a
short exposure in a similar or related
718 See infra Part IV.A.3.c.2.c.; final rule
§ ll.4(b)(2)(iii)(C).
719 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (stating that modern trading units generally
view individual positions as a bundle of
characteristics that contribute to their complete
portfolio). See also Federal Reserve Board, Trading
and Capital-Markets Activities Manual § 2000.1
(Feb. 1998) (‘‘The risk-measurement system should
also permit disaggregation of risk by type and by
customer, instrument, or business unit to effectively
support the management and control of risks.’’).
720 See ACLI (Feb. 2012); Fixed Income Forum/
Credit Roundtable; SIFMA et al. (Prop. Trading)
(Feb. 2012).
721 See final rule § ll.4(b)(4).
722 Final rule § ll.4(b)(4). For example, in the
case of derivatives, a trading desk’s financial
position will be the residual risks of the trading
desk’s open positions. For instance, an options desk
may have thousands of open trades at any given
time, including hedges, but the desk will manage,
among other risk factors, the trading desk’s portfolio
delta, gamma, rho, and volatility.
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instrument to yield a total exposure of
zero. Instead, such a combination may
reduce a trading desk’s economic
exposure to certain risk factors that are
common to both instruments, but it
would still retain any basis risk between
those financial instruments or
potentially generate a new risk exposure
in the case of purposeful hedging.
With respect to the frequency with
which a trading desk should determine
its financial exposure and the amount,
types, and risks of the financial
instruments in its market-maker
inventory, a trading desk’s financial
exposure and market-maker inventory
should be evaluated and monitored at a
frequency that is appropriate for the
trading desk’s trading strategies and the
characteristics of the financial
instruments the desk trades, including
historical intraday volatility. For
example, a trading desk that repeatedly
acquired and then terminated
significant financial exposures
throughout the day but that had little or
no financial exposure at the end of the
day should assess its financial exposure
based on its intraday activities, not
simply its end-of-day financial
exposure. The frequency with which a
trading desk’s financial exposure and
market-maker inventory will be
monitored and analyzed should be
specified in the trading desk’s
compliance program.
A trading desk’s financial exposure
reflects its aggregate risk exposures. The
types of ‘‘aggregate risks’’ identified in
the trading desk’s financial exposure
should reflect consideration of all
significant market factors relevant to the
financial instruments in which the
trading desk acts as market maker or
that the desk uses for risk management
purposes pursuant to this exemption,
including the liquidity, maturity, and
depth of the market for the relevant
types of financial instruments. Thus,
market factors reflected in a trading
desk’s financial exposure should
include all significant and relevant
factors associated with the products and
instruments in which the desk trades as
market maker or for risk management
purposes, including basis risk arising
from such positions.723 Similarly, an
assessment of the risks of the trading
desk’s market-maker inventory must
reflect consideration of all significant
723 As
discussed in Part IV.A.3.c.3., a banking
entity must establish, implement, maintain, and
enforce policies and procedures, internal controls,
analysis, and independent testing regarding the
financial instruments each trading desk stands
ready to purchase and sell and the products,
instruments, or exposures each trading desk may
use for risk management purposes. See final rule
§ ll.4(b)(2)(iii).
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market factors relevant to the financial
instruments in which the trading desk
makes a market. Importantly, a trading
desk’s financial exposure and the risks
of its market-maker inventory will
change based on the desk’s trading
activity (e.g., buying an instrument that
it did not previously hold, increasing its
position in an instrument, or decreasing
its position in an instrument) as well as
changing market conditions related to
instruments or positions managed by
the trading desk.
Because the final rule defines ‘‘trading
desk’’ based on operational
functionality rather than corporate
formality, a trading desk’s financial
exposure may include positions that are
booked in different affiliated legal
entities.724 The Agencies understand
that positions may be booked in
different legal entities for a variety of
reasons, including regulatory reasons.
For example, a trading desk that makes
a market in corporate bonds may book
its corporate bond positions in an SECregistered broker-dealer and may book
index CDS positions acquired for
hedging purposes in a CFTC-registered
swap dealer. A financial exposure that
reflects both the corporate bond position
and the index CDS position better
reflects the economic reality of the
trading desk’s risk exposure (i.e., by
showing that the risk of the corporate
bond position has been reduced by the
index CDS position).
In addition, a trading desk engaged in
market making-related activities in
compliance with the final rule may
direct another organizational unit of the
banking entity or an affiliate to execute
a risk-mitigating transaction on the
trading desk’s behalf.725 The other
organizational unit may rely on the
market-making exemption for these
purposes only if: (i) The other
organizational unit acts in accordance
with the trading desk’s risk management
policies and procedures established in
accordance with § ll.4(b)(2)(iii) of the
final rule; and (ii) the resulting riskmitigating position is attributed to the
trading desk’s financial exposure (and
not the other organizational unit’s
financial exposure) and is included in
the trading desk’s daily profit and loss
calculation. If another organizational
unit of the banking entity or an affiliate
establishes a risk-mitigating position for
the trading desk on its own accord (i.e.,
not at the direction of the trading desk)
724 Other statutory or regulatory requirements,
including those based on prudential safety and
soundness concerns, may prevent or limit a banking
entity from booking hedging positions in a legal
entity other than the entity taking the underlying
position.
725 See infra Part IV.A.3.c.4.
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or if the risk-mitigating position is
included in the other organizational
unit’s financial exposure or daily profit
and loss calculation, then the other
organizational unit must comply with
the requirements of the hedging
exemption for such activity.726 It may
not rely on the market-making
exemption under these circumstances. If
a trading desk engages in a riskmitigating transaction with a second
trading desk of the banking entity or an
affiliate that is also engaged in
permissible market making-related
activities, then the risk-mitigating
position would be included in the first
trading desk’s financial exposure and
the contra-risk would be included in the
second trading desk’s market-maker
inventory and financial exposure. The
Agencies believe the net effect of the
final rule is to allow individual trading
desks to efficiently manage their own
hedging and risk mitigation activities on
a holistic basis, while only allowing for
external hedging directed by staff
outside of the trading desk under the
additional requirements of the hedging
exemption.
To include in a trading desk’s
financial exposure either positions held
at an affiliated legal entity or positions
established by another organizational
unit on the trading desk’s behalf, a
banking entity must be able to provide
supervisors or examiners of any Agency
that has regulatory authority over the
banking entity pursuant to section
13(b)(2)(B) of the BHC Act with records,
promptly upon request, that identify
any related positions held at an
affiliated entity that are being included
in the trading desk’s financial exposure
for purposes of the market-making
exemption. Similarly, the supervisors
and examiners of any Agency that has
supervisory authority over the banking
entity that holds financial instruments
that are being included in another
trading desk’s financial exposure for
purposes of the market-making
exemption must have the same level of
access to the records of the trading
desk.727 Banking entities should be
prepared to provide all records that
identify all positions included in a
trading desk’s financial exposure and
where such positions are held.
726 Under these circumstances, the other
organizational unit would also be required to meet
the hedging exemption’s documentation
requirement for the risk-mitigating transaction. See
final rule § ll.5(c).
727 A banking entity must be able to provide such
records when a related position is held at an
affiliate, even if the affiliate and the banking entity
are not subject to the same Agency’s regulatory
jurisdiction.
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As an example of how a trading desk’s
market-maker inventory and financial
exposure will be analyzed under the
market-making exemption, assume a
trading desk makes a market in a variety
of U.S. corporate bonds and hedges its
aggregated positions with a combination
of exposures to corporate bond indexes
and specific name CDS in which the
desk does not make a market. To qualify
for the market-making exemption, the
trading desk would have to
demonstrate, among other things, that:
(i) The desk routinely stands ready to
purchase and sell the U.S. corporate
bonds, consistent with the requirement
of § ll.4(b)(2)(i) of the final rule, and
these instruments (or category of
instruments) are identified in the
trading desk’s compliance program; (ii)
the trading desk’s market-maker
inventory in U.S. corporate bonds is
designed not to exceed, on an ongoing
basis, the reasonably expected near term
demands of clients, customers, or
counterparties, consistent with the
analysis and limits established by the
banking entity for the trading desk; (iii)
the trading desk’s exposures to
corporate bond indexes and single name
CDS are designed to mitigate the risk of
its financial exposure, are consistent
with the products, instruments, or
exposures and the techniques and
strategies that the trading desk may use
to manage its risk effectively (and such
use continues to be effective), and do
not exceed the trading desk’s limits on
the amount, types, and risks of the
products, instruments, and exposures
the trading desk uses for risk
management purposes; and (iv) the
aggregate risks of the trading desk’s
exposures to U.S. corporate bonds,
corporate bond indexes, and single
name CDS do not exceed the trading
desk’s limits on the level of exposures
to relevant risk factors arising from its
financial exposure.
Our focus on the financial exposure of
a trading desk, rather than a trade-bytrade requirement, is designed to give
banking entities the flexibility to acquire
not only market-maker inventory, but
positions that facilitate market making,
such as positions that hedge marketmaker inventory.728 As commenters
pointed out, a trade-by-trade
requirement would view trades in
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728 The
Agencies believe it is appropriate to apply
the requirements of the exemption to the financial
exposure of a ‘‘trading desk,’’ rather than the
portfolio of a higher level of organization, for the
reasons discussed above, including our concern that
aggregating a large number of disparate positions
and exposures across a range of trading desks could
increase the risk of evasion. See supra Part
IV.A.3.c.1.c.i. (discussing the determination to
apply requirements at the trading desk level).
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isolation and could fail to recognize that
certain trades that are not customerfacing are nevertheless integral to
market making and financial
intermediation.729 The Agencies
understand that the risk-reducing effects
of combining large diverse portfolios
could, in certain instances, mask
otherwise prohibited proprietary
trading.730 However, the Agencies do
not believe that taking a transaction-bytransaction approach is necessary to
address this concern. Rather, the
Agencies believe that the broader
definitions of ‘‘financial exposure’’ and
‘‘market-maker inventory’’ coupled with
the tailored definition of ‘‘trading desk’’
facilitates the analysis of aggregate risk
exposures and positions in a manner
best suited to apply and evaluate the
market-making exemption.
In short, this approach is designed to
mitigate the costs of a trade-by-trade
analysis identified by commenters. The
Agencies recognize, however, that this
approach is only effective at achieving
the goals of the section 13 of the BHC
Act—promoting financial
intermediation and limiting speculative
risks within banking entities—if there
are limits on a trading desk’s financial
exposure. That is, a permissive marketmaking exemption that gives banking
entities maximum discretion in
acquiring positions to provide liquidity
runs the risk of also allowing banking
entities to engage in speculative trades.
As discussed more fully in the following
Parts of this SUPPLEMENTARY
INFORMATION, the final market-making
exemption provides a number of
controls on a trading desk’s financial
exposure. These controls include,
among others, a provision requiring that
a trading desk’s market-maker inventory
be designed not to exceed, on an
ongoing basis, the reasonably expected
near term demands of customers and
that any other financial instruments
managed by the trading desk be
designed to mitigate the risk of such
desk’s market-maker inventory. In
addition, the final market-making
exemption requires the trading desk’s
compliance program to include
appropriate risk and inventory limits
tied to the near term demand
requirement, as well as escalation
procedures if a trade would exceed such
limits. The compliance program, which
includes internal controls and
independent testing, is designed to
prevent instances where transactions
not related to providing financial
729 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012).
730 See, e.g., Occupy.
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intermediation services are part of a
desk’s financial exposure.
iii. Routinely Standing Ready To Buy
and Sell
The requirement to routinely stand
ready to buy and sell a type of financial
instrument in the final rule recognizes
that market making-related activities
differ based on the liquidity, maturity,
and depth of the market for the relevant
type of financial instrument. For
example, a trading desk acting as a
market maker in highly liquid markets
would engage in more regular quoting
activity than a market maker in less
liquid markets. Moreover, the Agencies
recognize that the maturity and depth of
the market also play a role in
determining the character of a market
maker’s activity.
As noted above, the standard of
‘‘routinely’’ standing ready to buy and
sell will differ across markets and asset
classes based on the liquidity, maturity,
and depth of the market for the type of
financial instrument. For instance, a
trading desk that is a market maker in
liquid equity securities generally should
engage in very regular or continuous
quoting and trading activities on both
sides of the market. In less liquid
markets, a trading desk should engage in
regular quoting activity across the
relevant type(s) of financial instruments,
although such quoting may be less
frequent than in liquid equity
markets.731 Consistent with the CFTC’s
and SEC’s interpretation of market
making in swaps and security-based
swaps for purposes of the definitions of
‘‘swap dealer’’ and ‘‘security-based
swap dealer,’’ ‘‘routinely’’ in the swap
market context means that the trading
desk should stand ready to enter into
swaps or security-based swaps at the
request or demand of a counterparty
more frequently than occasionally.732
The Agencies note that a trading desk
may routinely stand ready to enter into
derivatives on both sides of the market,
or it may routinely stand ready to enter
into derivatives on either side of the
market and then enter into one or more
offsetting positions in the derivatives
market or another market, particularly
in the case of relatively less liquid
derivatives. While a trading desk may
respond to requests to trade certain
731 Indeed, in the most specialized situations,
such quotations may only be provided upon
request. See infra note 735 and accompanying text
(discussing permissible block positioning).
732 The Agencies will consider factors similar to
those identified by the CFTC and SEC in connection
with this standard. See Further Definition of ‘‘Swap
Dealer,’’ ‘‘Security-Based Swap Dealer,’’ ‘‘Major
Swap Participant,’’ ‘‘Major Security-Based Swap
Participant’’ and ‘‘Eligible Contract Participant’’, 77
FR 30596, 30609 (May 23, 2012)
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products, such as custom swaps, even if
it does not normally quote in the
particular product, the trading desk
should hedge against the resulting
exposure in accordance with its
financial exposure and hedging
limits.733 Further, the Agencies
continue to recognize that market
makers in highly illiquid markets may
trade only intermittently or at the
request of particular customers, which
is sometimes referred to as trading by
appointment.734 A trading desk’s block
positioning activity would also meet the
terms of this requirement provided that,
from time to time, the desk engages in
block trades (i.e., trades of a large
quantity or with a high dollar value)
with customers.735
733 The Agencies recognize that, as noted by
commenters, preventing a banking entity from
conducting customized transactions with customers
may impact customers’ risk exposures or
transaction costs. See Goldman (Prop. Trading);
SIFMA (Asset Mgmt.) (Feb. 2012). The Agencies are
not prohibiting this activity under the final rule, as
discussed in this Part.
734 The Agencies have considered comments on
the issue of whether trading by appointment should
be permitted under the final market-making
exemption. The Agencies believe it is appropriate
to permit trading by appointment to the extent that
there is customer demand for liquidity in the
relevant products.
735 As noted in the preamble to the proposed rule,
the size of a block will vary among different asset
classes. The Agencies also stated in the proposal
that the SEC’s definition of ‘‘qualified block
positioner’’ in Rule 3b–8(c) under the Exchange Act
may serve as guidance for determining whether
block positioning activity qualifies for the marketmaking exemption. In referencing that rule as
guidance, the Agencies did not intend to imply that
a banking entity engaged in block positioning
activity would be required to meet all terms of the
‘‘qualified block positioner’’ definition at all times.
Nonetheless, a number of commenters indicated
that it was unclear when a banking entity would
need to act as a qualified block positioner in
accordance with Rule 3b–8(c) and expressed
concern that uncertainty could have a chilling effect
on a banking entity’s willingness to facilitate
customer block trades. See, e.g., RBC; SIFMA (Asset
Mgmt.) (Feb. 2012); Goldman (Prop. Trading). For
example, a few commenters stated that certain
requirements in Rule 3b–8(c) could cause fire sales
or general market uncertainty. See id. After
considering comments, the Agencies have decided
that the reference to Rule 3b–8(c) is unnecessary for
purposes of the final rule. In particular, the
Agencies believe that the requirements in the
market-making exemption provide sufficient
safeguards, and the additional requirements of the
‘‘qualified block positioner’’ definition may present
unnecessary burdens or redundancies with the rule,
as adopted. For example, the Agencies believe that
there is some overlap between § ll.4(b)(2)(ii) of
the exemption, which provides that the amount,
types, and risks of the financial instruments in the
trading desk’s market-maker inventory must be
designed not to exceed the reasonably expected
near term demands of clients, customers, or
counterparties, and Rule 3b–8(c)(iii), which
requires the sale of the shares comprising the block
as rapidly as possible commensurate with the
circumstances. In other words, the market-making
exemption would require a banking entity to
appropriately manage its inventory when engaged
in block positioning activity, but would not speak
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Regardless of the liquidity, maturity,
and depth of the market for a particular
type of financial instrument, a trading
desk should have a pattern of providing
price indications on either side of the
market and a pattern of trading with
customers on each side of the market. In
particular, in the case of relatively
illiquid derivatives or structured
instruments, it would not be sufficient
to demonstrate that a trading desk on
occasion creates a customized
instrument or provides a price quote in
response to a customer request. Instead,
the trading desk would need to be able
to demonstrate a pattern of taking these
actions in response to demand from
multiple customers with respect to both
long and short risk exposures in
identified types of instruments.
This requirement of the final rule
applies to a trading desk’s activity in
one or more ‘‘types’’ of financial
instruments.736 The Agencies recognize
that, in some markets, such as the
corporate bond market, a market maker
may regularly quote a subset of
instruments (generally the more liquid
directly to the timing element given the diversity
of markets to which the exemption applies.
As noted above, one commenter analyzed the
potential market impact of a complete restriction on
a market maker’s ability to provide direct liquidity
to help a customer execute a large block trade. See
supra note 682 and accompanying text. Because the
Agencies are not restricting a banking entity’s
ability to engage in block positioning in the manner
suggested by this commenter, the Agencies do not
believe that the final rule will cause the cited
market impact of incremental transaction costs
between $1.7 and $3.4 billion per year. The
Agencies address this commenter’s concern about
the impact of inventory metrics on a banking
entity’s willingness to engage in block trading in
Part IV.C.3. (discussing the metrics requirement in
the final rule and noting that metrics will not be
used to determine compliance with the rule but,
rather, will be monitored for patterns over time to
identify activities that may warrant further review).
One commenter appeared to request that block
trading activity not be subject to all requirements
of the market-making exemption. See SIFMA (Asset
Mgmt.) (Feb. 2012). Any activity conducted in
reliance on the market-making exemption,
including block trading activity, must meet the
requirements of the market-making exemption. The
Agencies believe the requirements in the final rule
are workable for block positioning activity and do
not believe it would be appropriate to subject block
positioning to lesser requirements than general
market-making activity. For example, trading in
large block sizes can expose a trading desk to
greater risk than market making in smaller sizes,
particularly absent risk management requirements.
Thus, the Agencies believe it is important for block
positioning activity to be subject to the same
requirements, including the requirements to
establish risk limits and risk management
procedures, as general market-making activity.
736 This approach is generally consistent with
commenters’ requested clarification that a trading
desk’s quoting activity will not be assessed on an
instrument-by-instrument basis, but rather across a
range of similar instruments for which the trading
desk acts as a market maker. See, e.g., RBC; SIFMA
et al. (Prop. Trading) (Feb. 2012); CIEBA; Goldman
(Prop. Trading).
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instruments), but may not provide
regular quotes in other related but less
liquid instruments that the market
maker is willing and available to trade.
Instead, the market maker would
provide a price for those instruments
upon request.737 The trading desk’s
activity, in the aggregate for a particular
type of financial instrument, indicates
whether it is engaged in activity that is
consistent with § ll.4(b)(2)(i) of the
final rule.
Notably, this requirement provides
that the types of financial instruments
for which the trading desk routinely
stands ready to purchase and sell must
be related to its authorized marketmaker inventory and it authorized
financial exposure. Thus, the types of
financial instruments for which the desk
routinely stands ready to buy and sell
should compose a significant portion of
its overall financial exposure. The only
other financial instruments contributing
to the trading desk’s overall financial
exposure should be those designed to
hedge or mitigate the risk of the
financial instruments for which the
trading desk is making a market. It
would not be consistent with the
market-making exemption for a trading
desk to hold only positions in, or be
exposed to, financial instruments for
which the trading desk is not a market
maker.738
A trading desk’s routine presence in
the market for a particular type of
financial instrument would not, on its
own, be sufficient grounds for relying
on the market-making exemption. This
is because the frequency at which a
trading desk is active in a particular
market would not, on its own,
distinguish between permitted market
making-related activity and
impermissible proprietary trading. In
response to comments, the final rule
provides that a trading desk also must
be willing and available to quote, buy
and sell, or otherwise enter into long
and short positions in the relevant
type(s) of financial instruments for its
737 See, e.g., Goldman (Prop. Trading); Morgan
Stanley; RBC; SIFMA et al. (Prop. Trading) (Feb.
2012).
738 The Agencies recognize that there could be
limited circumstances under which a trading desk’s
financial exposure does not relate to the types of
financial instruments that it is standing ready to
buy and sell for a short period of time. However,
the Agencies would expect for such occurrences to
be minimal. For example, this scenario could occur
if a trading desk unwinds a hedge position after the
market-making position has already been unwound
or if a trading desk acquires an anticipatory hedge
position prior to acquiring a market-making
position. As discussed more thoroughly in Part
IV.A.3.c.3., a banking entity must establish written
policies and procedures, internal controls, analysis,
and independent testing that establish appropriate
parameters around such activities.
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own account in commercially
reasonable amounts and throughout
market cycles.739 Importantly, a trading
desk would not meet the terms of this
requirement if it provides wide
quotations relative to prevailing market
conditions and is not engaged in other
activity that evidences a willingness or
availability to provide intermediation
services.740 Under these circumstances,
a trading desk would not be standing
ready to purchase and sell because it is
not genuinely quoting or trading with
customers.
In the context of this requirement,
‘‘commercially reasonable amounts’’
means that the desk generally must be
willing to quote and trade in sizes
requested by other market
participants.741 For trading desks that
engage in block trading, this would
include block trades requested by
customers, and this language is not
meant to restrict a trading desk from
acting as a block positioner. Further, a
trading desk must act as a market maker
on an appropriate basis throughout
market cycles and not only when it is
most favorable for it to do so.742 For
example, a trading desk should be
facilitating customer needs in both
upward and downward moving markets.
As discussed further in Part
IV.A.3.c.3., the financial instruments the
trading desk stands ready to buy and
sell must be identified in the trading
desk’s compliance program.743 Certain
requirements in the final exemption
apply to the amount, types, and risks of
these financial instruments that a
trading desk can hold in its marketmaker inventory, including the near
term customer demand requirement 744
739 See,
e.g., Occupy; Better Markets (Feb. 2012).
commenter expressed concern that a
banking entity may be able to rely on the marketmaking exemption when it is providing only wide,
out of context quotes. See Occupy.
741 As discussed below, this may include
providing quotes in the interdealer trading market.
742 Algorithmic trading strategies that only trade
when market factors are favorable to the strategy’s
objectives or that otherwise frequently exit the
market would not be considered to be standing
ready to purchase or sell a type of financial
instrument throughout market cycles and, thus,
would not qualify for the market-making
exemption. The Agencies believe this addresses
commenters’ concerns about high-frequency trading
activities that are only active in the market when
it is believed to be profitable, rather than to
facilitate customers. See, e.g., Better Markets (Feb.
2012). The Agencies are not, however, prohibiting
all high-frequency trading activities under the final
rule or otherwise limiting high-frequency trading by
banking entities by imposing a resting period on
their orders, as requested by certain commenters.
See, e.g., Better Markets (Feb. 2012); Occupy; Public
Citizen.
743 See final rule § ll.4(b)(2)(iii)(A).
744 See final rule § ll.4(b)(2)(ii).
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and the need to have certain risk and
inventory limits.745
In response to the proposed
requirement that a trading desk or other
organizational unit hold itself out, some
commenters requested that the Agencies
limit the availability of the marketmaking exemption to trading in
particular asset classes or trading on
particular venues (e.g., organized
trading platforms). The Agencies are not
limiting the availability of the marketmaking exemption in the manner
requested by these commenters.746
Provided there is customer demand for
liquidity in a type of financial
instrument, the Agencies do not believe
the availability of the market-making
exemption should depend on the
liquidity of that type of financial
instrument or the ability to trade such
instruments on an organized trading
platform. The Agencies see no basis in
the statutory text for either approach
and believe that the likely harms to
investors seeking to trade affected
instruments (e.g., reduced ability to
purchase or sell a particular instrument,
potentially higher transaction costs) and
market quality (e.g., reduced liquidity)
that would arise under such an
approach would not be justified,747
particularly in light of the minimal
benefits that might result from
restricting or eliminating a banking
entity’s ability to hold less liquid assets
in connection with its market makingrelated activities. The Agencies believe
these commenters’ concerns are
adequately addressed by the final rule’s
requirements in the market-making
final rule § ll.4(b)(2)(iii)(C).
example, a few commenters requested that
the rule prohibit banking entities from market
making in assets classified as Level 3 under FAS
157. See supra note 651 and accompanying text.
The Agencies continue to believe that it would be
inappropriate to incorporate accounting standards
in the rule because accounting standards could
change in the future without consideration of the
potential impact on the final rule. See Joint
Proposal, 76 FR 68,859 n.101 (explaining why the
Agencies declined to incorporate certain accounting
standards in the proposed rule); CFTC Proposal, 77
FR 8344 n.107.
Further, a few commenters suggested that the
exemption should only be available for trading on
an organized trading facility. This type of limitation
would require significant and widespread market
structure changes (with associated systems and
infrastructure costs) in a relatively short period of
time, as market making in certain assets is primarily
or wholly conducted in the OTC market, and
organized trading platforms may not currently exist
for these assets. The Agencies do not believe that
the costs of such market structure changes would
be warranted for purposes of this rule.
747 As discussed above, a number of commenters
expressed concern about the potential market
impacts of the perceived restrictions on market
making under the proposed rule, particularly with
respect to less liquid markets, such as the corporate
bond market. See, e.g., Prof. Duffie; Wellington;
BlackRock; ICI.
745 See
746 For
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5597
exemption that are designed to ensure
that a trading desk cannot hold risk in
excess of what is appropriate to provide
intermediation services designed not to
exceed, on an ongoing basis, the
reasonably expected near term demands
of clients, customers, or counterparties.
In response to comments on the
proposed interpretation regarding
anticipatory position-taking,748 the
Agencies note that the near term
demand requirement in the final rule
addresses when a trading desk may take
positions in anticipation of reasonably
expected near term customer
demand.749 The Agencies believe this
approach is generally consistent with
the comments the Agencies received on
this issue.750 In addition, the Agencies
note that modifications to the proposed
near term demand requirement in the
final rule also address commenters
concerns on this issue.751
2. Near Term Customer Demand
Requirement
a. Proposed Near Term Customer
Demand Requirement
Consistent with the statute, the
proposed rule required that the trading
desk or other organizational unit’s
market making-related activities be,
with respect to the financial instrument,
designed not to exceed the reasonably
expected near term demands of clients,
customers, or counterparties.752 This
requirement is intended to prevent a
trading desk from taking a speculative
proprietary position that is unrelated to
customer needs as part of the desk’s
748 Joint Proposal, 76 FR 68,871 (stating that
‘‘bona fide market making-related activity may
include taking positions in securities in
anticipation of customer demand, so long as any
anticipatory buying or selling activity is reasonable
and related to clear, demonstrable trading interest
of clients, customers, or counterparties’’); CFTC
Proposal, 77 FR 8356–8357; See also Morgan
Stanley (requesting certain revisions to more closely
track the statute); SIFMA et al. (Prop. Trading) (Feb.
2012); Goldman (Prop. Trading); Chamber (Feb.
2012); Comm. on Capital Markets Regulation;
SIFMA (Asset Mgmt.) (Feb. 2012).
749 See final rule § ll.4(b)(2)(ii); infra Part
IV.A.3.c.2.c.
750 See BoA; SIFMA et al. (Prop. Trading) (Feb.
2012); Goldman (Prop. Trading); Morgan Stanley;
Chamber (Feb. 2012); Comm. on Capital Markets
Regulation; SIFMA (Asset Mgmt.) (Feb. 2012).
751 For example, some commenters suggested that
the final rule allow market makers to make
individualized assessments of anticipated customer
demand, based on their expertise and experience,
and account for differences between liquid and less
liquid markets. See Chamber (Feb. 2012); ISDA
(Feb. 2012). The final rule allows such assessments,
based on historical customer demand and other
relevant factors, and recognizes that near term
demand may differ based on the liquidity, maturity,
and depth of the market for a particular type of
financial instrument. See infra Part IV.A.3.c.2.c.iii.
752 See proposed rule § ll.4(b)(2)(iii).
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purported market making-related
activities.753
In the proposal, the Agencies stated
that a banking entity’s expectations of
near term customer demand should
generally be based on the unique
customer base of the banking entity’s
specific market-making business lines
and the near term demand of those
customers based on particular factors,
beyond a general expectation of price
appreciation. The Agencies further
stated that they would not expect the
activities of a trading desk or other
organizational unit to qualify for the
market-making exemption if the trading
desk or other organizational unit is
engaged wholly or principally in trading
that is not in response to, or driven by,
customer demands, regardless of
whether those activities promote price
transparency or liquidity. The proposal
stated that, for example, a trading desk
or other organizational unit of a banking
entity that is engaged wholly or
principally in arbitrage trading with
non-customers would not meet the
terms of the proposed rule’s marketmaking exemption.754
With respect to market making in a
security that is executed on an exchange
or other organized trading facility, the
proposal provided that a market maker’s
activities are generally consistent with
reasonably expected near term customer
demand when such activities involve
passively providing liquidity by
submitting resting orders that interact
with the orders of others in a nondirectional or market-neutral trading
strategy and the market maker is
registered, if the exchange or organized
trading facility registers market makers.
Under the proposal, activities on an
exchange or other organized trading
facility that primarily take liquidity,
rather than provide liquidity, would not
qualify for the market-making
exemption, even if conducted by a
registered market maker.755
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b. Comments Regarding the Proposed
Near Term Customer Demand
Requirement
As noted above, the proposed near
term customer demand requirement
would implement language found in the
statute’s market-making exemption.756
Some commenters expressed general
support for this requirement.757 For
example, these commenters emphasized
753 See Joint Proposal, 76 FR 68,871; CFTC
Proposal, 77 FR 8357.
754 See id.
755 See Joint Proposal, 76 FR 68,871–68,872;
CFTC Proposal, 77 FR 8357.
756 See supra Part IV.A.3.c.2.a.
757 See, e.g., Sens. Merkley & Levin (Feb. 2012);
Flynn & Fusselman; Better Markets (Feb. 2012).
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that the proposed near term demand
requirement is an important component
that restricts disguised position-taking
or market making in illiquid markets.758
Several other commenters expressed
concern that the proposed requirement
is too restrictive 759 because, for
example, it may impede a market
maker’s ability to build or retain
inventory 760 or may impact a market
maker’s willingness to engage in block
trading.761 Comments on particular
aspects of this proposed requirement are
discussed below, including the
proposed interpretation of this
requirement in the proposal, the
requirement’s potential impact on
market maker inventory, potential
differences in this standard across asset
classes, whether it is possible to predict
near term customer demand, and
whether the terms ‘‘client,’’ ‘‘customer,’’
or ‘‘counterparty’’ should be defined for
purposes of the exemption.
i. The Proposed Guidance for
Determining Compliance With the Near
Term Customer Demand Requirement
As discussed in more detail above, the
proposal set forth proposed guidance on
how a banking entity may comply with
the proposed near term customer
demand requirement.762 With respect to
the language indicating that a banking
entity’s determination of near term
customer demand should generally be
based on the unique customer base of a
specific market-making business line
(and not merely an expectation of future
price appreciation), one commenter
758 See Better Markets (Feb. 2012); Sens. Merkley
& Levin (Feb. 2012).
759 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Chamber (Feb. 2012); T. Rowe Price; SIFMA
(Asset Mgmt.) (Feb. 2012); ACLI (Feb. 2012);
MetLife; Comm. on Capital Markets Regulation;
CIEBA; Credit Suisse (Seidel); SSgA (Feb. 2012);
IAA (stating that the proposed requirement is too
subjective and would be difficult to administer in
a range of scenarios); Barclays; Prof. Duffie.
760 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); T. Rowe Price; CIEBA; Credit Suisse (Seidel);
Barclays; Wellington; MetLife; Chamber (Feb. 2012);
RBC; Prof. Duffie; ICI (Feb. 2012); SIFMA (Asset
Mgmt.) (Feb. 2012). The Agencies respond to these
comments in Part IV.A.3.c.2.c., infra. For a
discussion of comments regarding inventory
management activity conducted in connection with
market making, See Part IV.A.3.c.2.b.vi., infra.
761 See, e.g., ACLI (Feb. 2012); MetLife; Comm. on
Capital Markets Regulation (noting that a market
maker may need to hold significant inventory to
accommodate potential block trade requests). Two
of these commenters stated that a market maker
may provide a worse price or may be unwilling to
intermediate a large customer position if the market
maker has to determine whether holding such
position will meet the near term demand
requirement, particularly if the market maker would
be required to sell the block position over a short
period of time. See ACLI (Feb. 2012); MetLife.
These comments are addressed in Part
IV.A.3.c.2.c.iii., infra.
762 See supra Part IV.A.3.c.2.a.
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stated that it is unclear how a banking
entity would be able to make such
determinations in markets where trades
occur infrequently and customer
demand is hard to predict.763
Several commenters expressed
concern about the proposal’s statement
that a trading desk or other
organizational unit engaged wholly or
principally in trading that is not in
response to, or driven by, customer
demands (e.g., arbitrage trading with
non-customers) would not qualify for
the exemption, regardless of whether
the activities promote price
transparency or liquidity.764 In
particular, commenters stated that it
would be difficult for a market-making
business to try to divide its activities
that are in response to customer demand
(e.g., customer intermediation and
hedging) from activities that promote
price transparency and liquidity (e.g.,
interdealer trading to test market depth
or arbitrage trading) in order to
determine their proportionality.765
Another commenter stated that, as a
matter of organizational efficiency, firms
will often restrict arbitrage trading
strategies to certain specific individual
traders within the market-making
organization, who may sometimes be
referred to as a ‘‘desk,’’ and expressed
concern that this would be prohibited
under the rule.766
In response to the proposed
interpretation regarding market making
on an exchange or other organized
trading facility (and certain similar
language in proposed Appendix B),767
several commenters indicated that the
reference to passive submission of
resting orders may be too restrictive and
provided examples of scenarios where
market makers may need to use market
or marketable limit orders.768 For
763 See SIFMA et al. (Prop. Trading) (Feb. 2012).
Another commenter suggested that the Agencies
‘‘establish clear criteria that reflect appropriate
revenue from changes in the bid-ask spread,’’ noting
that a legitimate market maker should be both
selling and buying in a rising market (or, likewise,
in a declining market). Public Citizen.
764 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); BoA; ICI (Feb. 2012); ICI Global;
Vanguard; SSgA (Feb. 2012); See also infra Part
IV.A.3.c.2.b.viii. (discussing comments on whether
arbitrage trading should be permitted under the
market-making exemption under certain
circumstances).
765 See Goldman (Prop. Trading); RBC. One of
these commenters agreed, however, that a trading
desk that is ‘‘wholly’’ engaged in trading that is
unrelated to customer demand should not qualify
for the proposed market-making exemption. See
Goldman (Prop. Trading).
766 See JPMC.
767 See Joint Proposal, 76 FR 68,871–68,872;
CFTC Proposal, 77 FR 8357.
768 See, e.g., NYSE Euronext; SIFMA et al. (Prop.
Trading) (Feb. 2012); Goldman (Prop. Trading);
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example, many of these commenters
stated that market makers may need to
enter market or marketable limit orders
to: (i) build or reduce inventory; 769 (ii)
address order imbalances on an
exchange by, for example, using market
orders to lessen volatility and restore
pricing equilibrium; (iii) hedge marketmaking positions; (iv) create markets; 770
(v) test the depth of the markets; (vi)
ensure that ETFs, American depositary
receipts (‘‘ADRs’’), options, and other
instruments remain appropriately
priced; 771 and (vii) respond to
movements in prices in the markets.772
Two commenters noted that distinctions
between limit and market or marketable
limit orders may not be workable in the
international context, where exchanges
may not use the same order types as
U.S. trading facilities.773
A few commenters also addressed the
proposed use of a market maker’s
exchange registration status as part of
the analysis.774 Two commenters stated
that the proposed rule should not
require a market maker to be registered
with an exchange to qualify for the
proposed market-making exemption.
According to these commenters, there
are a large number of exchanges and
organized trading facilities on which
market makers may need to trade to
maintain liquidity across the markets
and to provide customers with favorable
prices. These commenters indicated that
any restrictions or burdens on such
trading may decrease liquidity or make
it harder to provide customers with the
best price for their trade.775 One
commenter, however, stated that the
exchange registration requirement is
RBC. Comments on proposed Appendix B are
discussed further in Part IV.A.3.c.8.b., infra. This
issue is addressed in note 939 and its
accompanying text, infra.
769 Some commenters stated that market makers
may need to use market or marketable limit orders
to build inventory in anticipation of customer
demand or in connection with positioning a block
trade for a customer. See SIFMA et al. (Prop.
Trading) (Feb. 2012); RBC; Goldman (Prop.
Trading). Two of these commenters noted that these
order types may be needed to dispose of positions
taken into inventory as part of market making. See
RBC; Goldman (Prop. Trading).
770 See NYSE Euronext.
771 See Goldman (Prop. Trading).
772 See SIFMA et al. (Prop. Trading) (Feb. 2012).
773 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading).
774 See NYSE Euronext; SIFMA et al. (Prop.
Trading) (Feb. 2012); Goldman (Prop. Trading);
Occupy. See also infra notes 940 to 941 and
accompanying text (addressing these comments).
775 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(stating that trading units may currently register as
market makers with particular, primary exchanges
on which they trade, but will serve in a marketmaking capacity on other trading venues from time
to time); Goldman (Prop. Trading) (noting that there
are more than 12 exchanges and 40 alternative
trading systems currently trading U.S. equities).
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reasonable and further supported
adding a requirement that traders
demonstrate adherence to the same or
commensurate standards in markets
where registration is not possible.776
Some commenters recommended
certain modifications to the proposed
analysis. For example, a few
commenters requested that the rule
presume that a trading unit is engaged
in permitted market making-related
activity if it is registered as a market
maker on a particular exchange or
organized trading facility.777 In support
of this recommendation, one commenter
represented that it would be warranted
because registered market makers
directly contribute to maintaining liquid
and orderly markets and are subject to
extensive regulatory requirements in
that capacity.778 Another commenter
suggested that the Agencies instead use
metrics to compare, in the aggregate and
over time, the liquidity that a market
maker makes rather than takes as part of
a broader consideration of the marketmaking character of the relevant trading
activity.779
ii. Potential Inventory Restrictions and
Differences Across Asset Classes
A number of commenters expressed
concern that the proposed requirement
776 See Occupy. In the alternative, this commenter
would require all market making to be performed
on an exchange or organized trading facility. See id.
777 See NYSE Euronext (recognizing that
registration status is not necessarily conclusive of
engaging in market making-related activities);
SIFMA et al. (Prop. Trading) (Feb. 2012) (stating
that to the extent a trading unit is registered on a
particular exchange or organized trading facility for
any type of financial instrument, all of its activities
on that exchange or organized trading facility
should be presumed to be market making);
Goldman (Prop. Trading). See also infra note 940
(responding to these comments). Two commenters
noted that certain exchange rules may require
market makers to deal for their own account under
certain circumstances in order to maintain fair and
orderly markets. See NYSE Euronext (discussing
NYSE rules); Goldman (Prop. Trading) (discussing
NYSE and CBOE rules). For example, according to
these commenters, NYSE Rule 104(f)(ii) requires a
market maker to maintain fair and orderly markets,
which may involve dealing for their own account
when there is a lack of price continuity, lack of
depth, or if a disparity between supply and demand
exists or is reasonably anticipated. See id.
778 See Goldman (Prop. Trading). This commenter
further stated that trading activities of exchange
market makers may be particularly difficult to
evaluate with customer-facing metrics (because
‘‘specialist’’ market makers may not have
‘‘customers’’), so conferring a positive presumption
of compliance on such market makers would ensure
that they can continue to contribute to liquidity,
which benefits customers. This commenter noted
that, for example, NYSE designated market makers
(‘‘DMMs’’) are generally prohibited from dealing
with customers and companies must ‘‘wall off’’ any
trading units that act as DMMs. See id. (citing NYSE
Rule 98).
779 See id. (stating that spread-related metrics,
such as Spread Profit and Loss, may be useful for
this purpose).
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5599
may unduly restrict a market maker’s
ability to manage its inventory.780
Several of these commenters stated that
limitations on inventory would be
especially problematic for market
making in less liquid markets, like the
fixed-income market, where customer
demand is more intermittent and
positions may need to be held for a
longer period of time.781 Some
commenters stated that the Agencies’
proposed interpretation of this
requirement would restrict a market
maker’s inventory in a manner that is
inconsistent with the statute. These
commenters indicated that the
‘‘designed’’ and ‘‘reasonably expected’’
language of the statute seem to
recognize that market makers must
anticipate customer requests and
accumulate sufficient inventory to meet
those reasonably expected demands.782
In addition, one commenter represented
that a market maker must have wide
latitude and incentives for initiating
trades, rather than merely reacting to
customer requests for quotes, to
properly risk manage its positions or to
prepare for anticipated customer
demand or supply.783 Many
commenters requested certain
modifications to the proposed
requirement to limit its impact on
market maker inventory.784
780 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); T. Rowe Price; CIEBA; Credit Suisse (Seidel);
Barclays; Wellington; MetLife; Chamber (Feb. 2012);
RBC; Prof. Duffie; ICI (Feb. 2012); SIFMA (Asset
Mgmt.) (Feb. 2012). These concerns are addressed
in Part IV.A.3.c.2.c., infra.
781 See, e.g., SIFMA (Asset Mgmt.) (Feb. 2012); T.
Rowe Price; CIEBA; ICI (Feb. 2012); RBC.
782 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Chamber (Feb. 2012).
783 See Prof. Duffie. However, another commenter
stated that a legitimate market maker should
respond to customer demand rather than initiate
transactions, which is indicative of prohibited
proprietary trading. See Public Citizen.
784 See Credit Suisse (Seidel) (suggesting that the
rule allow market makers to build inventory in
products where they believe customer demand will
exist, regardless of whether the inventory can be
tied to a particular customer in the near term or to
historical trends in customer demand); Barclays
(recommending the rule require that ‘‘the market
making-related activity is conducted by each
trading unit such that its activities (including the
maintenance of inventory) are designed not to
exceed the reasonably expected near term demands
of clients, customers, or counterparties consistent
with the market and trading patterns of the relevant
product, and consistent with the reasonable
judgment of the banking entity where such demand
cannot be determined with reasonable accuracy’’);
CIEBA. In addition, some commenters suggested an
interpretation that would provide greater discretion
to market makers to enter into trades based on
factors such as experience and expertise dealing in
the market and market exigencies. See SIFMA et al.
(Prop. Trading) (Feb. 2012); Chamber (Feb. 2012).
Two commenters suggested that the proposed
requirement should be interpreted to permit
market-making activity as it currently exists. See
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Commenters’ views on the importance
of permitting inventory management
activity in connection with market
making are discussed below in Part
IV.A.3.c.2.b.vi.
Several commenters requested that
the Agencies recognize that near term
customer demand may vary across
different markets and asset classes and
implement this requirement flexibly.785
In particular, many of these commenters
emphasized that the concept of ‘‘near
term demand’’ should be different for
less liquid markets, where transactions
may occur infrequently, and for liquid
markets, where transactions occur more
often.786 One commenter requested that
the Agencies add the phrase ‘‘based on
the characteristics of the relevant market
and asset class’’ to the end of the
requirement to explicitly acknowledge
these differences.787
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iii. Predicting Near Term Customer
Demand
Commenters provided views on
whether and, if so how, a banking entity
may be able to predict near term
customer demand for purposes of the
proposed requirement.788 For example,
two commenters suggested ways in
which a banking entity could predict
near term customer demand.789 One of
these commenters indicated that
banking entities should be able to utilize
current risk management tools to predict
near term customer demand, although
these tools may need to be adapted to
comply with the rule’s requirements.
According to this commenter, dealers
commonly assess the following factors
across product lines, which can relate to
expected customer demand: (i) Recent
volumes and customer trends; (ii)
trading patterns of specific customers;
(iii) analysis of whether the firm has an
ability to win new customer business;
(iv) comparison of the current market
conditions to prior similar periods; (v)
liquidity of large investors; and (vi) the
MetLife; ACLI (Feb. 2012). One commenter
requested that the proposed requirement be moved
to Appendix B of the rule to provide greater
flexibility to consider facts and circumstances of a
particular activity. See JPMC.
785 See CIEBA; Morgan Stanley; RBC; ICI (Feb.
2012); ISDA (Feb. 2012); Comm. on Capital Markets
Regulation; Alfred Brock. The Agencies respond to
these comments in Part IV.A.3.c.2.c.ii., infra.
786 See ICI (Feb. 2012); CIEBA (stating that, absent
a different interpretation for illiquid instruments,
market makers will err on the side of holding less
inventory to avoid sanctions for violating the rule);
RBC.
787 See Morgan Stanley.
788 See Wellington; MetLife; SIFMA et al. (Prop.
Trading) (Feb. 2012); Sens. Merkley & Levin (Feb.
2012); Chamber (Feb. 2012); FTN; RBC; Alfred
Brock. These comments are addressed in Part
IV.A.3.c.2.c.iii., infra.
789 See Sens. Merkley & Levin (Feb. 2012); FTN.
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schedule of maturities in customers’
existing positions.790 Another
commenter stated that the
reasonableness of a market maker’s
inventory can be measured by looking to
the specifics of the particular market,
the size of the customer base being
served, and expected customer demand,
which banking entities should be
required to take into account in both
their inventory practices and policies
and their actual inventories. This
commenter recommended that the rule
permit a banking entity to assume a
position under the market-making
exemption if it can demonstrate a track
record or reasonable expectation that it
can dispose of a position in the near
term.791
Some commenters, however,
emphasized that reasonably expected
near term customer demand cannot
always be accurately predicted.792
Several of these commenters requested
the Agencies clarify that banking
entities will not be subject to regulatory
sanctions if reasonably anticipated near
term customer demand does not
materialize.793 One commenter further
noted that a banking entity entering a
new market, or gaining or losing
customers, may need greater flexibility
in applying the near term demand
requirement because its anticipated
demand may fluctuate.794
iv. Potential Definitions of ‘‘Client,’’
‘‘Customer,’’ or ‘‘Counterparty’’
Appendix B of the proposal discussed
the proposed meaning of the term
‘‘customer’’ in the context of permitted
market making-related activity.795 In
790 See FTN. The commenter further indicated
that errors in estimating customer demand are
managed through kick-out rules and oversight by
risk managers and committees, with latitude in
decisions being closely related to expected or
empirical costs of hedging positions until they
result in trading with counterparties. See id.
791 See Sens. Merkley & Levin (Feb. 2012) (stating
that banking entities should be required to collect
inventory data, evaluate the data, develop policies
on how to handle particular positions, and make
regular adjustments to ensure a turnover of assets
commensurate with near term demand of
customers). This commenter also suggested that the
rule specify the types of inventory metrics that
should be collected and suggested that the rate of
inventory turnover would be helpful. See id.
792 See MetLife; Chamber (Feb. 2012); RBC;
CIEBA; Wellington; ICI (Feb. 2012); Alfred Brock.
This issue is addressed in Part IV.A.3.c.2.c.iii.,
infra.
793 See ICI (Feb. 2012); CIEBA; RBC; Wellington;
Invesco.
794 See CIEBA.
795 See Joint Proposal, 76 FR 68,960; CFTC
Proposal, 77 FR 8439. More specifically, Appendix
B stated: ‘‘In the context of market making in a
security that is executed on an organized trading
facility or an exchange, a ‘customer’ is any person
on behalf of whom a buy or sell order has been
submitted by a broker-dealer or any other market
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addition, the proposal inquired whether
the terms ‘‘client,’’ ‘‘customer,’’ or
‘‘counterparty’’ should be defined in the
rule for purposes of the market-making
exemption.796 Commenters expressed
varying views on the proposed
interpretations in the proposal and on
whether these terms should be defined
in the final rule.797
With respect to the proposed
interpretations of the term ‘‘customer’’
in Appendix B, one commenter agreed
with the proposed interpretations and
expressed the belief that the
interpretations will allow interdealer
market making where brokers or other
dealers act as customers. However, this
commenter also requested that the
Agencies expressly incorporate
providing liquidity to other brokers and
dealers into the rule text.798 Another
commenter similarly stated that instead
of focusing solely on customer demand,
the rule should be clarified to reflect
that demand can come from other
dealers or future customers.799
In response to the proposal’s question
about whether the terms ‘‘client,’’
‘‘customer,’’ and ‘‘counterparty’’ should
be further defined, a few commenters
stated that that the terms should not be
defined in the rule.800 Other
participant. In the context of market making in a
[financial instrument] in an OTC market, a
‘customer’ generally would be a market participant
that makes use of the market maker’s
intermediation services, either by requesting such
services or entering into a continuing relationship
with the market maker with respect to such
services.’’ Id. On this last point, the proposal
elaborated that in certain cases, depending on the
conventions of the relevant market (e.g., the OTC
derivatives market), such a ‘‘customer’’ may
consider itself or refer to itself more generally as a
‘‘counterparty.’’ See Joint Proposal, 76 FR 68,960
n.2; CFTC Proposal, 77 FR 8439 n.2.
796 See Joint Proposal, 76 FR 68,874; CFTC
Proposal, 77 FR 8359. In particular, Question 99
states: ‘‘Should the terms ‘client,’ ‘customer,’ or
‘counterparty’ be defined for purposes of the market
making exemption? If so, how should these terms
be defined? For example, would an appropriate
definition of ‘customer’ be: (i) A continuing
relationship in which the banking entity provides
one or more financial products or services prior to
the time of the transaction; (ii) a direct and
substantive relationship between the banking entity
and a prospective customer prior to the transaction;
(iii) a relationship initiated by the banking entity to
a prospective customer to induce transactions; or
(iv) a relationship initiated by the prospective
customer with a view to engaging in transactions?’’
Id.
797 Comments on this issue are addressed in Part
IV.A.3.c.2.c.i., infra.
798 See SIFMA et al. (Prop. Trading) (Feb. 2012).
See also Credit Suisse (Seidel); RBC (requesting that
the Agencies recognize ‘‘wholesale’’ market making
as permissible and representing that ‘‘[i]t is
irrelevant to an investor whether market liquidity
is provided by a broker-dealer with whom the
investor maintains a customer account, or whether
that broker-dealer looks to another dealer for market
liquidity’’).
799 See Comm. on Capital Markets Regulation.
800 See FTN; ISDA (Feb. 2012); Alfred Brock.
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commenters indicated that further
definition of these terms would be
appropriate.801 Some of these
commenters suggested that there should
be greater limitations on who can be
considered a ‘‘customer’’ under the
rule.802 These commenters generally
indicated that a ‘‘customer’’ should be a
person or institution with whom the
banking entity has a continuing, or a
direct and substantive, relationship
prior to the time of the transaction.803 In
the case of a new customer, some of
these commenters suggested requiring a
relationship initiated by the prospective
customer with a view to engaging in
transactions.804 A few commenters
indicated that a party should not be
considered a client, customer, or
counterparty if the banking entity: (i)
originates a financial product and then
finds a counterparty to take the other
side of the transaction; 805 or (ii) engages
in transactions driven by algorithmic
trading strategies.806 Three commenters
requested more permissive definitions
of these terms.807 According to one of
these commenters, because these terms
are listed in the disjunctive in the
801 See Japanese Bankers Ass’n.; Credit Suisse
(Seidel); Occupy; AFR et al. (Feb. 2012); Public
Citizen.
802 See AFR et al. (Feb. 2012); Occupy; Public
Citizen. One of these commenters also requested
that the Agencies remove the terms ‘‘client’’ and
‘‘counterparty’’ from the proposed near term
demand requirement. See Occupy.
803 See AFR et al. (Feb. 2012); Occupy; Public
Citizen. These commenters stated that other
banking entities should never be ‘‘customers’’ under
the rule. See id. In addition, one of these
commenters would further prevent a banking
entity’s employees and covered funds from being
‘‘customers’’ under the rule. See AFR et al. (Feb.
2012).
804 See AFR et al. (Feb. 2012) (providing a similar
definition for the term ‘‘client’’ as well); Public
Citizen.
805 See AFR et al. (Feb. 2012); Public Citizen. See
also Sens. Merkley & Levin (Feb. 2012) (stating that
a banking entity’s activities that involve attempting
to sell clients financial instruments that it
originated, rather than facilitating a secondary
market for client trades in previously existing
financial products, should be analyzed under the
underwriting exemption, not the market-making
exemption; in addition, compiling inventory of
financial instruments that the bank originated
should be viewed as proprietary trading).
806 See AFR et al. (Feb. 2012).
807 See Credit Suisse (Seidel) (stating that
‘‘customer’’ should be explicitly defined to include
any counterparty to whom a banking entity is
providing liquidity); ISDA (Feb. 2012)
(recommending that, if the Agencies decide to
define these terms, a ‘‘counterparty’’ should be
defined as the entity on the other side of a
transaction, and the terms ‘‘client’’ and ‘‘customer’’
should not be interpreted to require a relationship
beyond the isolated provision of a transaction);
Japanese Bankers Ass’n. (requesting that it be
clearly noted that interbank participants can be
customers for interbank market makers).
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statute, the broadest term—a
‘‘counterparty’’—should prevail.808
v. Interdealer Trading and Trading for
Price Discovery or To Test Market Depth
With respect to interdealer trading,
many commenters expressed concern
that the proposed rule could be
interpreted to restrict a market maker’s
ability to engage in interdealer
trading.809 As a general matter,
commenters attributed these concerns to
statements in proposed Appendix B 810
or to the Customer-Facing Trade Ratio
metric in proposed Appendix A.811 A
number of commenters requested that
the rule be modified to clearly recognize
interdealer trading as a component of
permitted market making-related
activity 812 and suggested ways in which
this could be accomplished (e.g.,
through a definition of ‘‘customer’’ or
‘‘counterparty’’).813
808 See ISDA (Feb. 2012). This commenter’s
primary position was that further definitions are not
required and could create additional and
unnecessary complexity. See id.
809 See, e.g., JPMC; Morgan Stanley; Goldman
(Prop. Trading); Chamber (Feb. 2012); MetLife;
Credit Suisse (Seidel); BoA; ACLI (Feb. 2012); RBC;
AFR et al. (Feb. 2012); ISDA (Feb. 2012); Oliver
Wyman (Dec. 2011); Oliver Wyman (Feb. 2012). A
few commenters noted that the proposed rule
would permit a certain amount of interdealer
trading. See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (citing statements in the proposal providing
that a market maker’s ‘‘customers’’ vary depending
on the asset class and market in which
intermediation services are provided and
interpreting such statements as allowing interdealer
market making where brokers or other dealers act
as ‘‘customers’’ within the proposed construct);
Goldman (Prop. Trading) (stating that interdealer
trading related to hedging or exiting a customer
position would be permitted, but expressing
concern that requiring each banking entity to justify
each of its interdealer trades as being related to one
of its own customers would be burdensome and
would reduce the effectiveness of the interdealer
market). Commenters’ concerns regarding
interdealer trading are addressed in Part
IV.A.3.c.2.c.i., infra.
810 See infra Part IV.A.3.c.8.
811 See, e.g., JPMC; SIFMA et al. (Prop. Trading)
(Feb. 2012); Oliver Wyman (Feb. 2012) (recognizing
that the proposed rule did not include specific
limits on interdealer trading, but expressing
concern that explicit or implicit limits could be
established by supervisors during or after the
conformance period).
812 See MetLife; SIFMA et al. (Prop. Trading)
(Feb. 2012); RBC; Credit Suisse (Seidel); JPMC;
BoA; ACLI (Feb. 2012); AFR et al. (Feb. 2012); ISDA
(Feb. 2012); Goldman (Prop. Trading); Oliver
Wyman (Feb. 2012).
813 See RBC (suggesting that explicitly
incorporating liquidity provision to other brokers
and dealers in the market-making exemption would
be consistent with the statute’s reference to meeting
the needs of ‘‘counterparties,’’ in addition to the
needs of clients and customers); AFR et al. (Feb.
2012) (recognizing that the ability to manage
inventory through interdealer transactions should
be accommodated in the rule, but recommending
that this activity be conditioned on a market maker
having an appropriate level of inventory after an
interdealer transaction); Goldman (Prop. Trading)
(representing that the Agencies could evaluate and
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5601
Commenters emphasized that
interdealer trading provides certain
market benefits, including increased
market liquidity; 814 more efficient
matching of customer order flow; 815
greater hedging options to reduce
risks; 816 enhanced ability to accumulate
inventory for current or near term
customer demand, work down
concentrated positions arising from a
customer trade, or otherwise exit a
position acquired from a customer; 817
and general price discovery among
dealers.818 Regarding the impact of
interdealer trading on a market maker’s
ability to intermediate customer needs,
one commenter studied the potential
impact of interdealer trading limits—in
combination with inventory limits—on
trading in the U.S. corporate bond
market. According to this commenter, if
interdealer trading had been prohibited
and a market maker’s inventory had
been limited to the average daily
volume of the market as a whole, 69
percent of customer trades would have
been prevented.819 Some commenters
stated that a banking entity would be
less able or willing to provide marketmaking services to customers if it could
not engage in interdealer trading.820
monitor the amount of interdealer trading that is
consistent with a particular trading unit’s market
making-related or hedging activity through the
customer-facing activity category of metrics); Oliver
Wyman (Feb. 2012) (recommending removal or
modification of any metrics or principles that
would indicate that interdealer trading is not
permitted).
814 See Prof. Duffie; MetLife; ACLI (Feb. 2012);
BDA (Feb. 2012).
815 See Oliver Wyman (Dec. 2011); Oliver Wyman
(Feb. 2012); MetLife; ACLI (Feb. 2012). See also
Thakor Study (stating that, when a market maker
provides immediacy to a customer, it relies on
being able to unwind its positions at opportune
times by trading with other market makers, who
may have knowledge about impending orders form
their own customers that may induce them to trade
with the market maker).
816 See MetLife; ACLI (Feb. 2012); Goldman
(Prop. Trading); Morgan Stanley; Oliver Wyman
(Dec. 2011); Oliver Wyman (Feb. 2012).
817 See Goldman (Prop. Trading); Chamber (Feb.
2012). See also Prof. Duffie (stating that a market
maker acquiring a position from a customer may
wish to rebalance its inventory relatively quickly
through the interdealer network, which is often
more efficient than requesting immediacy from
another customer or waiting for another customer
who wants to take the opposite side of the trade).
818 See Chamber (Feb. 2012); Goldman (Prop.
Trading).
819 See Oliver Wyman (Feb. 2012) (basing its
finding on data from 2009). This commenter also
represented that the natural level of interdealer
volume in the U.S. corporate bond market made up
16 percent of total trading volume in 2010. See id.
820 See Goldman (Prop. Trading); Morgan Stanley.
See also BDA (Feb. 2012) (stating that if dealers in
the fixed-income market are not able to trade with
other dealers to ‘‘cooperate with each other to
provide adequate liquidity to the market as a
whole,’’ an essential source of liquidity will be
eliminated from the market and existing values of
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As noted above, a few commenters
stated that market makers may use
interdealer trading for price discovery
purposes.821 Some commenters
separately discussed the importance of
this activity and requested that, when
conducted in connection with marketmaking activity, trading for price
discovery be considered permitted
market making-related activity under
the rule.822 Commenters indicated that
price discovery-related trading results in
certain market benefits, including
enhancing the accuracy of prices for
customers,823 increasing price
efficiency, preventing market
instability,824 improving market
liquidity, and reducing overall costs for
market participants.825 As a converse,
one of these commenters stated that
restrictions on such activity could result
in market makers setting their prices too
high, exposing them to significant risk
and causing a reduction of marketmaking activity or widening of spreads
to offset the risk.826 One commenter
further requested that trading to test
market depth likewise be permitted
under the market-making exemption.827
This commenter represented that the
Agencies would be able to evaluate the
extent to which trading for price
discovery and market depth are
consistent with market making-related
activities for a particular market through
a combination of customer-facing
activity metrics, including the Inventory
Risk Turnover metric, and knowledge of
a banking entity’s trading business
developed by regulators as part of the
supervisory process.828
vi. Inventory Management
Several commenters requested that
the rule provide banking entities with
greater discretion to manage their
inventories in connection with market
making-related activity, including
acquiring or disposing of positions in
anticipation of customer demand.829
Commenters represented that market
makers need to be able to build, manage,
and maintain inventories to facilitate
customer demand. These commenters
further stated that the rule needs to
provide some degree of flexibility for
inventory management activities, as
inventory needs may differ based on
market conditions or the characteristics
of a particular instrument.830 A few
commenters cited legislative history in
support of allowing banking entities to
hold and manage inventory in
connection with market making-related
activities.831 Several commenters noted
benefits that are associated with a
market maker’s ability to appropriately
manage its inventory, including being
able to meet reasonably anticipated
future client, customer, or counterparty
demand; 832 accommodating customer
transactions more quickly and at
favorable prices; reducing near term
price volatility (in the case of selling a
customer block position); 833 helping
maintain an orderly market and provide
the best price to customers (in the case
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828 See
fixed income securities will decline and become
volatile, harming both investors who currently hold
such positions and issuers, who will experience
increased interest costs).
821 See Chamber (Feb. 2012); Goldman (Prop.
Trading).
822 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Chamber (Feb. 2012); Goldman (Prop. Trading). One
commenter provided the following example of such
activity: If Security A and Security B have some
price correlation but neither trades regularly, then
a trader may execute a trade in Security A for price
discovery purposes, using the price of Security A
to make an informed bid-ask market to a customer
in Security B. See SIFMA et al. (Prop. Trading)
(Feb. 2012).
823 See Goldman (Prop. Trading); Chamber (Feb.
2012) (stating that this type of trading is necessary
in more illiquid markets); SIFMA et al. (Prop.
Trading) (Feb. 2012).
824 See Goldman (Prop. Trading).
825 See Chamber (Feb. 2012).
826 See id.
827 See Goldman (Prop. Trading). This commenter
represented that market makers often make trades
with other dealers to test the depth of the markets
at particular price points and to understand where
supply and demand exist (although such trading is
not conducted exclusively with other dealers). This
commenter stated that testing the depth of the
market is necessary to provide accurate prices to
customers, particularly when customers Seeks to
enter trades in amounts larger than the amounts
offered by dealers who have sent indications to
inter-dealer brokers. See id.
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id.
e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); Goldman (Prop.
Trading); MFA; RBC. Inventory management is
addressed in Part IV.A.3.c.2.c., infra.
830 See, e.g., MFA (stating that it is critical for
banking entities to continue to be able to maintain
sufficient levels of inventory, which is dynamic in
nature and requires some degree of flexibility in
application); RBC (requesting that the Agencies
explicitly acknowledge that, depending on market
conditions or the characteristics of a particular
security, it may be appropriate or necessary for a
firm to maintain inventories over extended periods
of time in the course of market making-related
activities).
831 See, e.g., RBC; NYSE Euronext; Fidelity. These
commenters cited a colloquy in the Congressional
Record between Senator Bayh and Senator Dodd, in
which Senator Bayh stated: ‘‘With respect to
[section 13 of the BHC Act], the conference report
states that banking entities are not prohibited from
purchasing and disposing of securities and other
instruments in connection with underwriting or
market-making activities, provided that activity
does not exceed the reasonably expected near-term
demands of clients, customers, or counterparties. I
want to clarify this language would allow banks to
maintain an appropriate dealer inventory and
residual risk positions, which are essential parts of
the market-making function. Without that
flexibility, market makers would not be able to
provide liquidity to markets.’’ 156 Cong. Rec. S5906
(daily ed. July 15, 2010) (statement of Sen. Bayh).
832 See, e.g., RBC.
833 See Goldman (Prop. Trading).
829 See,
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of accumulating long or short positions
in anticipation of a large customer sale
or purchase); 834 ensuring that markets
continue to have sufficient liquidity; 835
fostering a two-way market; and
establishing a market-making
presence.836 Some commenters noted
that market makers may need to
accumulate inventory to meet customer
demand for certain products or under
certain trading scenarios, such as to
create units of structured products (e.g.,
ETFs and asset-backed securities) 837
and in anticipation of an index
rebalance.838
Commenters also expressed views
with respect to how much discretion a
banking entity should have to manage
its inventory under the exemption and
how to best monitor inventory levels.
For example, one commenter
recommended that the rule allow
market makers to build inventory in
products where they believe customer
demand will exist, regardless of whether
the inventory can be tied to a particular
customer in the near term or to
historical trends in customer
demand.839 A few commenters
suggested that the Agencies provide
banking entities with greater discretion
to accumulate inventory, but discourage
market makers from holding inventory
for long periods of time by imposing
increasingly higher capital requirements
on aged inventory.840 One commenter
834 See
id.
MFA.
836 See RBC.
837 See Goldman (Prop. Trading); BoA.
838 See Oliver Wyman (Feb. 2012). As this
commenter explained, some mutual funds and ETFs
track major equity indices and, when the
composition of an index changes (e.g., due to the
addition or removal of a security or to rising or
falling values of listed shares), an announcement is
made and all funds tracking the index need to
rebalance their portfolios. According to the
commenter, banking entities may need to step in to
provide liquidity for rebalances of less liquid
indices because trades executed on the open market
would substantially affect share prices. The
commenter estimated that if market makers are not
able to provide direct liquidity for rebalance trades,
investors tracking these indices could potentially
pay incremental costs of $600 million to $1.8
billion every year. This commenter identified the
proposed inventory metrics in Appendix A as
potentially limiting a banking entity’s willingness
or ability to facilitate index rebalance trades. See id.
Two other commenters also discussed the index
rebalancing scenario. See Prof. Duffie; Thakor
Study. Index rebalancing is addressed in note 931,
infra.
839 See Credit Suisse (Seidel).
840 See CalPERS; Vanguard. These commenters
represented that placing increasing capital
requirements on aged inventory would ease the
rule’s impact on investor liquidity, allow banking
entities to internalize the cost of continuing to hold
a position at the expense of its ability to take on
new positions, and potentially decrease the
possibility of a firm realizing a loss on a position
by decreasing the time such position is held. See
id. One commenter noted that some banking entities
835 See
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represented that a trading unit’s
inventory management practices could
be monitored with the Inventory Risk
Turnover metric, in conjunction with
other metrics.841
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vii. Acting as an Authorized Participant
or Market Maker in Exchange-Traded
Funds
With respect to ETF trading,
commenters generally requested
clarification that a banking entity can
serve as an authorized participant
(‘‘AP’’) to an ETF issuer or can engage
in ETF market making under the
proposed exemption.842 According to
commenters, APs may engage in the
following types of activities with respect
to ETFs: (i) trading directly with the
ETF issuer to create or redeem ETF
shares, which involves trading in ETF
shares and the underlying
components; 843 (ii) trading to maintain
price alignment between the ETF shares
and the underlying components; 844 (iii)
traditional market-making activity; 845
already use this approach to manage risk on their
market-making desks. See Vanguard. See also
Capital Group (suggesting that one way to
implement the statutory exemption would be to
charge a trader or a trading desk for positions held
on its balance sheet beyond set time periods and to
increase the charge at set intervals). These
comments are addressed in note 923, infra.
841 See Goldman (Prop. Trading) (representing
that the Inventory Risk Turnover metric will allow
the Agencies to evaluate the length of time that a
trading unit tends to hold risk positions in
inventory and whether that holding time is
consistent with market making-related activities in
the relevant market).
842 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); BoA; ICI (stating that an AP may trade
with the ETF issuer in different capacities—in
connection with traditional market-making activity,
on behalf of customers, or for the AP’s own
account); ICI Global (discussing non-U.S. ETFs
specifically); Vanguard; SSgA (Feb. 2012). One
commenter represented that an AP’s transactions in
ETFs do not create risks associated with proprietary
trading because, when an AP trades with an ETF
issuer for its own account, the AP typically enters
into an offsetting transaction in the underlying
portfolio of securities, which cancels out
investment risk and limits the AP’s exposure to the
difference between the market price for ETF shares
and the ETF’s net asset value (‘‘NAV’’). See
Vanguard.
With respect to market-making activity in an ETF,
several commenters noted that market makers play
an important role in maintaining price alignment by
engaging in arbitrage transactions between the ETF
shares and the shares of the underlying
components. See, e.g., JPMC; Goldman (Prop.
Trading) (making similar statement with respect to
ADRs as well); SSgA (Feb. 2012); SIFMA et al.
(Prop. Trading) (Feb. 2012); Credit Suisse (Seidel);
RBC. AP and market maker activity in ETFs are
addressed in Part IV.A.3.c.2.c.i., infra.
843 See SIFMA et al. (Prop. Trading) (Feb. 2012);
BoA; ICI (Feb. 2012) ICI Global; Vanguard; SSgA
(Feb. 2012).
844 See JPMC; Goldman (Prop. Trading); SIFMA et
al. (Prop. Trading) (Feb. 2012); SSgA (Feb. 2012);
ICI (Feb. 2012) ICI Global.
845 See ICI Global; ICI (Feb. 2012) SIFMA et al.
(Prop. Trading) (Feb. 2012); BoA.
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(iv) ‘‘seeding’’ a new ETF by entering
into several initial creation transactions
with an ETF issuer and holding the ETF
shares, possibly for an extended period
of time, until the ETF establishes regular
trading and liquidity in the secondary
markets; 846 (v) ‘‘create to lend’’
transactions, where an AP enters a
creation transaction with the ETF issuer
and lends the ETF shares to an
investor; 847 and (vi) hedging.848 A few
commenters noted that an AP may not
engage in traditional market-making
activity in the relevant ETF and
expressed concern that the proposed
rule may limit a banking entity’s ability
to act in an AP capacity.849 One
commenter estimated that APs that are
banking entities make up between 20
percent to 100 percent of creation and
redemption activity for individual ETFs,
with an average of approximately 35
percent of creation and redemption
activity across all ETFs attributed to
banking entities. This commenter
expressed the view that, if the rule
limits banking entities’ ability to serve
as APs, then individual investors’
investments in ETFs will become more
expensive due to higher premiums and
discounts versus the ETF’s NAV.850
A number of commenters stated that
certain requirements of the proposed
exemption may limit a banking entity’s
ability to serve as AP to an ETF,
including the proposed near term
customer demand requirement,851 the
proposed source of revenue
requirement,852 and language in the
846 See
BoA; ICI (Feb. 2012); ICI Global.
BoA (stating that lending the ETF shares
to an investor gives the investor a more efficient
way to hedge its exposure to assets correlated with
those underlying the ETF).
848 See ICI Global; ICI (Feb. 2012).
849 See, e.g., Vanguard (noting that APs may not
engage in market-making activity in the ETF and
expressing concern that if AP activities are not
separately permitted, banking entities may exit or
not enter the ETF market); SSgA (Feb. 2012) (stating
that APs are under no obligation to make markets
in ETF shares and requiring such an obligation
would discourage banking entities from acting as
APs); ICI (Feb. 2012).
850 See SSgA (Feb. 2012). This commenter further
stated that as of 2011, an estimated 3.5 million—
or 3 percent—of U.S. households owned ETFs and,
as of September 2011, ETFs represented assets of
approximately $951 billion. See id.
851 See BoA; Vanguard (stating that this
determination may be particularly difficult in the
case of a new ETF).
852 See BoA. This commenter noted that the
proposed source of revenue requirement could be
interpreted to prevent a banking entity acting as AP
from entering into creation and redemption
transactions, ‘‘Seeding’’ an ETF, engaging in ‘‘create
to lend’’ transactions, and performing secondary
market making in an ETF because all of these
activities require an AP to build an inventory—
either in ETF shares or the underlying
components—which often result in revenue
attributable to price movements. See id.
5603
proposal regarding arbitrage trading.853
With respect to the proposed near term
customer demand requirement, a few
commenters noted that this requirement
could prevent an AP from building
inventory to assemble creation units.854
Two other commenters expressed the
view that the ETF issuer would be the
banking entity’s ‘‘counterparty’’ when
the banking entity trades directly with
the ETF issuer, so this trading and
inventory accumulation would meet the
terms of the proposed requirement.855
To permit banking entities to act as APs,
two commenters suggested that trading
in the capacity of an AP should be
deemed permitted market makingrelated activity, regardless of whether
the AP is acting as a traditional market
maker.856
viii. Arbitrage or Other Activities That
Promote Price Transparency and
Liquidity
In response to a question in the
proposal,857 a number of commenters
stated that certain types of arbitrage
activity should be permitted under the
market-making exemption.858 For
example, some commenters stated that a
banking entity’s arbitrage activity
should be considered market making to
the extent the activity is driven by
creating markets for customers tied to
the price differential (e.g., ‘‘box’’
strategies, ‘‘calendar spreads,’’ merger
arbitrage, ‘‘Cash and Carry,’’ or basis
trading) 859 or to the extent that demand
is predicated on specific price
relationships between instruments (e.g.,
ETFs, ADRs) that market makers must
847 See
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853 Commenters noted that this language would
restrict an AP from engaging in price arbitrage to
maintain efficient markets in ETFs. See Vanguard;
RBC; Goldman (Prop. Trading); JPMC; SIFMA et al.
(Prop. Trading) (Feb. 2012). See supra Part
IV.A.3.c.2.a. (discussing the proposal’s proposed
interpretation regarding arbitrage trading).
854 See BoA; Vanguard (stating that this
determination may be particularly difficult in the
case of a new ETF).
855 See ICI Global; ICI (Feb. 2012).
856 See ICI (Feb. 2012) ICI Global. These
commenters provided suggested rule text on this
issue and suggested that the Agencies could require
a banking entity’s compliance policies and internal
controls to take a comprehensive approach to the
entirety of an AP’s trading activity, which would
facilitate easy monitoring of the activity to ensure
compliance. See id.
857 See Joint Proposal, 76 FR 68,873 (question 91)
(inquiring whether the proposed exemption should
be modified to permit certain arbitrage trading
activities engaged in by market makers that promote
liquidity or price transparency but do not service
client, customer, or counterparty demand); CFTC
Proposal, 77 FR 8359.
858 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); FTN; RBC; ISDA (Feb. 2012). Arbitrage
trading is further discussed in Part IV.A.3.c.2.c.i.,
infra.
859 See SIFMA et al. (Prop. Trading) (Feb. 2012).
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maintain.860 Similarly, another
commenter suggested that arbitrage
activity that aligns prices should be
permitted, such as index arbitrage, ETF
arbitrage, and event arbitrage.861 One
commenter noted that many markets,
such as futures and options markets,
rely on arbitrage activities of market
makers for liquidity purposes and to
maintain convergence with underlying
instruments for cash-settled options,
futures, and index-based products.862
Commenters stated that arbitrage trading
provides certain market benefits,
including enhanced price
transparency,863 increased market
efficiency,864 greater market
liquidity,865 and general benefits to
customers.866 A few commenters noted
that certain types of hedging activity
may appear to have characteristics of
arbitrage trading.867
Commenters suggested certain
methods for permitting and monitoring
arbitrage trading under the exemption.
For example, one commenter suggested
a framework for permitting certain
arbitrage within the market-making
exemption, with requirements such as:
(i) Common personnel with marketmaking activity; (ii) policies that cover
the timing and appropriateness of
arbitrage positions; (iii) time limits on
arbitrage positions; and (iv)
compensation that does not reward
successful arbitrage, but instead pools
any such revenues with market-making
profits and losses.868 A few commenters
860 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC.
861 See Credit Suisse (Seidel).
862 See RBC.
863 See SIFMA et al. (Prop. Trading) (Feb. 2012).
864 See Credit Suisse (Seidel); RBC.
865 See RBC.
866 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; FTN; ISDA (Feb. 2012) (stating that arbitrage
activities often yield positions that are ultimately
put to use in serving customer demand and
representing that the process of consistently trading
makes a dealer ready and available to serve
customers on a competitive basis).
867 See JPMC (stating that firms commonly
organize their market-making activities so that risks
delivered to client-facing desks are aggregated and
transferred by means of internal transactions to a
single utility desk (which hedges all of the risks in
the aggregate), and this may optically bear some
characteristics of arbitrage, although the commenter
requested that such activity be recognized as
permitted market making-related activity under the
rule); ISDA (Feb. 2012) (stating that in some swaps
markets, dealers hedge through multiple
instruments, which can give an impression of
arbitrage in a function that is risk reducing; for
example, a dealer in a broad index equity swap may
simultaneously hedge in baskets of stocks, futures,
and ETFs). But See Sens. Merkley & Levin (Feb.
2012) (‘‘When banks use complex hedging
techniques or otherwise engage in trading that is
suggestive of arbitrage, regulators should require
them to provide evidence and analysis
demonstrating what risk is being reduced.’’).
868 See FTN.
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represented that, if permitted under the
rule, the Agencies would be able to
monitor arbitrage activities for patterns
of impermissible proprietary trading
through the use of metrics, as well as
compliance and examination tools.869
Other commenters stated that the
exemption should not permit certain
types of arbitrage. One commenter
stated that the rule should ensure that
relative value and complex arbitrage
strategies cannot be conducted.870
Another commenter expressed the view
that the market-making exemption
should not permit any type of arbitrage
transactions. This commenter stated
that, in the event that liquidity or
transparency is inhibited by a lack of
arbitrage trading, a market maker should
be able to find a customer who would
seek to benefit from it.871
ix. Primary Dealer Activities
A number of commenters requested
that the market-making exemption
permit banking entities to meet their
primary dealer obligations in foreign
jurisdictions, particularly if trading in
foreign sovereign debt is not separately
exempted in the final rule.872 According
to commenters, a banking entity may be
obligated to perform the following
activities in its capacity as a primary
dealer: undertaking to maintain an
orderly market, preventing or correcting
any price dislocations,873 and bidding
on each issuance of the relevant
jurisdiction’s sovereign debt.874
Commenters expressed concern that a
banking entity’s trading activity as
primary dealer may not comply with the
proposed near term customer demand
requirement 875 or the proposed source
869 See SIFMA et al. (Prop. Trading) (Feb. 2012);
RBC; Goldman (Prop. Trading). One of these
commenters stated that the customer-facing activity
category of metrics, as well as other metrics, would
be available to evaluate whether the trading unit is
engaged in a directly customer-facing business and
the extent to which its activities are consistent with
the market-making exemption. See Goldman (Prop.
Trading).
870 See Johnson & Prof. Stiglitz. See also AFR et
al. (Feb. 2012) (noting that arbitrage, spread, or
carry trades are a classic type of proprietary trade).
871 See Occupy.
872 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012) (stating that permitted activities should
include trading necessary to meet the relevant
jurisdiction’s primary dealer and other
requirements); JPMC (indicating that the exemption
should cover all of a firm’s activities that are
necessary or reasonably incidental to its acting as
a primary dealer in a foreign government’s debt
securities); Goldman (Prop. Trading); Banco de
´
Mexico; IIB/EBF. See infra notes 905 to 906 and
accompanying text (addressing these comments).
873 See Goldman (Prop. Trading).
874 See Banco de Mexico.
´
875 See JPMC; Banco de Mexico. These
´
commenters stated that a primary dealer is required
to assume positions in foreign sovereign debt even
when near term customer demand is unpredictable.
See id.
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of revenue requirement.876 To address
the first issue, one commenter stated
that the final rule should clarify that a
banking entity acting as a primary
dealer of foreign sovereign debt is
engaged in primary dealer activity in
response to the near term demands of
the sovereign, which should be
considered a client, customer, or
counterparty of the banking entity.877
Another commenter suggested that the
Agencies permit primary dealer
activities through commentary stating
that fulfilling primary dealer obligations
will not be included in determinations
of whether the market-making
exemption applies to a trading unit.878
x. New or Bespoke Products or
Customized Hedging Contracts
Several commenters indicated that the
proposed exemption does not
adequately address market making in
new or bespoke products, including
structured, customer-driven
transactions, and requested that the rule
be modified to clearly permit such
activity.879 Many of these commenters
emphasized the role such transactions
play in helping customers hedge the
unique risks they face.880 Commenters
stated that, as a result, limiting a
banking entity’s ability to conduct such
transactions would subject customers to
increased risks and greater transaction
costs.881 One commenter suggested that
the Agencies explicitly state that a
banking entity’s general willingness to
engage in bespoke transactions is
sufficient to make it a market maker in
unique products for purposes of the
rule.882
Other commenters stated that banking
entities should be limited in their ability
to rely on the market-making exemption
to conduct transactions in bespoke or
876 See Banco de Mexico (stating that primary
´
dealers need to be able to profit from their positions
in sovereign debt, including by holding significant
positions in anticipation of future price movements,
so that the primary dealer business is financially
attractive); IIB/EBF (stating that primary dealers
may actively Seek to profit from price and interest
rate movements based on their debt holdings,
which governments support as providing muchneeded liquidity for securities that are otherwise
purchased largely pursuant to buy-and-hold
strategies of institutional investors and other
entities Seeking safe returns and liquidity buffers).
877 See Goldman (Prop. Trading).
878 See SIFMA et al. (Prop. Trading) (Feb. 2012).
879 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); JPMC; Goldman (Prop.
Trading); SIFMA (Asset Mgmt.) (Feb. 2012). This
issue is addressed in Part IV.A.3.c.1.c.iii., supra,
and Part IV.A.3.c.2.c.iii., infra.
880 See Credit Suisse (Seidel); Goldman (Prop.
Trading); SIFMA (Asset Mgmt.) (Feb. 2012).
881 See Goldman (Prop. Trading); SIFMA (Asset
Mgmt.) (Feb. 2012).
882 See SIFMA (Asset Mgmt.) (Feb. 2012).
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customized derivatives.883 For example,
one commenter suggested that a banking
entity be required to disaggregate such
derivatives into liquid risk elements and
illiquid risk elements, with liquid risk
elements qualifying for the marketmaking exemption and illiquid risk
elements having to be conducted on a
riskless principal basis under § __
.6(b)(1)(ii) of the proposed rule.
According to this commenter, such an
approach would not impact the end user
customer.884 Another commenter stated
that a banking entity making a market in
bespoke instruments should be required
both to hold itself out in accordance
with § __.4(b)(2)(ii) of the proposed rule
and to demonstrate the purchase and
the sale of such an instrument.885
c. Final Near Term Customer Demand
Requirement
Consistent with the statute, § __
.4(b)(2)(ii) of the final rule’s marketmaking exemption requires that the
amount, types, and risks of the financial
instruments in the trading desk’s
market-maker inventory be designed not
to exceed, on an ongoing basis, the
reasonably expected near term demands
of clients, customers, or counterparties,
based on certain market factors and
analysis.886 As discussed above in Part
IV.A.3.c.1.c.ii., the trading desk’s
market-maker inventory consists of
positions in financial instruments in
which the trading desk stands ready to
purchase and sell consistent with the
final rule.887 The final rule requires the
financial instruments to be identified in
the trading desk’s compliance program.
Thus, this requirement focuses on a
trading desk’s positions in financial
instruments for which it acts as market
maker. These positions of a trading desk
are more directly related to the demands
of customers than positions in financial
instruments used for risk management
purposes, but in which the trading desk
does not make a market. As noted
above, a position or exposure that is
included in a trading desk’s marketmaker inventory will remain in its
market-maker inventory for as long as
the position or exposure is managed by
the trading desk. As a result, the trading
883 See
AFR et al. (Feb. 2012); Public Citizen.
AFR et al. (Feb. 2012).
885 See Public Citizen.
886 The final rule includes certain refinements to
the proposed standard, which would have required
that the market making-related activities of the
trading desk or other organizational unit that
conducts the purchase or sale are, with respect to
the financial instrument, designed not to exceed the
reasonably expected near term demands of clients,
customers, or counterparties. See proposed rule
§ __.4(b)(2)(iii).
887 See supra Part IV.A.3.c.1.c.ii.; final rule
§ __.4(b)(5).
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884 See
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desk must continue to account for that
position or exposure, together with
other positions and exposures in its
market-maker inventory, in determining
whether the amount, types, and risks of
its market-maker inventory are designed
not to exceed, on an ongoing basis, the
reasonably expected near term demands
of customers.
While the near term customer demand
requirement directly applies only to the
trading desk’s market-maker inventory,
this does not mean a trading desk may
establish other positions, outside its
market-maker inventory, that exceed
what is needed to manage the risks of
the trading desk’s market makingrelated activities and inventory. Instead,
a trading desk must have limits on its
market-maker inventory, the products,
instruments, and exposures the trading
desk may use for risk management
purposes, and its aggregate financial
exposure that are based on the factors
set forth in the near term customer
demand requirement, as well as other
relevant considerations regarding the
nature and amount of the trading desk’s
market making-related activities. A
banking entity must establish,
implement, maintain, and enforce a
limit structure, as well as other
compliance program elements (e.g.,
those specifying the instruments a
trading desk trades as a market maker or
may use for risk management purposes
and providing for specific risk
management procedures), for each
trading desk that are designed to
prevent the trading desk from engaging
in trading activity that is unrelated to
making a market in a particular type of
financial instrument or managing the
risks associated with making a market in
that type of financial instrument.888
To clarify the application of this
standard in response to comments,889
the final rule provides two factors for
assessing whether the amount, types,
and risks of the financial instruments in
the trading desk’s market-maker
inventory are designed not to exceed, on
an ongoing basis, the reasonably
expected near term demands of clients,
customers, or counterparties.
Specifically, the following must be
considered under the revised standard:
(i) The liquidity, maturity, and depth of
the market for the relevant type of
financial instrument(s),890 and (ii)
888 See infra Part IV.A.3.c.3. (discussing the
compliance program requirements); final rule
§ __.4(b)(2)(iii).
889 See supra Part IV.A.3.c.2.b.i.
890 This language has been added to the final rule
to respond to commenters’ concerns that the
proposed near term demand requirement would be
unworkable in less liquid markets or would
otherwise restrict a market maker’s ability to hold
PO 00000
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5605
demonstrable analysis of historical
customer demand, current inventory of
financial instruments, and market and
other factors regarding the amount,
types, and risks of or associated with
positions in financial instruments in
which the trading desk makes a market,
including through block trades. Under
the final rule, a banking entity must
account for these considerations when
establishing risk and inventory limits
for each trading desk.891
For purposes of this provision,
‘‘demonstrable analysis’’ means that the
analysis for determining the amount,
types, and risks of financial instruments
a trading desk may manage in its
market-maker inventory, in accordance
with the near term demand requirement,
must be based on factors that can be
demonstrated in a way that makes the
analysis reviewable. This may include,
among other things, the normal trading
records of the trading desk and market
information that is readily available and
retrievable. If the analysis cannot be
supported by the banking entity’s books
and records and available market data,
on their own, then the other factors
utilized must be identified and
documented and the analysis of those
factors together with the facts gathered
from the trading and market records
must be identified in a way that makes
it possible to test the analysis.
Importantly, a determination of
whether a trading desk’s market-maker
inventory is appropriate under this
requirement will take into account
reasonably expected near term customer
demand, including historical levels of
customer demand, expectations based
on market factors, and current demand.
For example, at any particular time, a
trading desk may acquire a position in
a financial instrument in response to a
customer’s request to sell the financial
instrument or in response to reasonably
expected customer buying interest for
such instrument in the near term.892 In
addition, as discussed below, this
requirement is not intended to impede
a trading desk’s ability to engage in
and manage its inventory in less liquid markets. See
supra Part IV.A.3.c.2.b.ii. In addition, this provision
is substantially similar to one commenter’s
suggested approach of adding the phrase ‘‘based on
the characteristics of the relevant market and asset
class’’ to the proposed requirement, but the
Agencies have added more specificity about the
relevant characteristics that should be taken into
consideration. See Morgan Stanley.
891 See infra Part IV.A.3.c.3.
892 As discussed further below, acquiring a
position in a financial instrument in response to
reasonably expected customer demand would not
include creating a structured product for which
there is no current customer demand and, instead,
soliciting customer demand during or after its
creation. See infra note 938 and accompanying text;
Sens. Merkley & Levin (Feb. 2012).
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certain market making-related activities
that are consistent with and needed to
facilitate permissible trading with its
clients, customers, or counterparties,
such as inventory management and
interdealer trading. These activities
must, however, be consistent with the
analysis conducted under the final rule
and the trading desk’s limits discussed
below.893 Moreover, as explained below,
the banking entity must also have in
place escalation procedures to address,
analyze, and document trades made in
response to customer requests that
would exceed one of a trading desk’s
limits.
The near term demand requirement is
an ongoing requirement that applies to
the amount, types, and risks of the
financial instruments in the trading
desk’s market-maker inventory. For
instance, a trading desk may acquire
exposures as a result of entering into
market-making transactions with
customers that are within the desk’s
market-marker inventory and financial
exposure limits. Even if the trading desk
is appropriately managing the risks of
its market-maker inventory, its marketmaker inventory still must be consistent
with the analysis of the reasonably
expected near term demands of clients,
customers, and counterparties and the
liquidity, maturity and depth of the
market for the relevant instruments in
the inventory. Moreover, the trading
desk must take action to ensure that its
financial exposure does not exceed its
financial exposure limits.894 A trading
desk may not maintain an exposure in
its market-maker inventory, irrespective
of customer demand, simply because
the exposure is hedged and the resulting
financial exposure is below the desk’s
financial exposure limit. In addition, the
amount, types, and risks of financial
instruments in a trading desk’s marketmaker inventory would not be
consistent with permitted marketmaking activities if, for example, the
trading desk has a pattern or practice of
retaining exposures in its market-maker
inventory, while refusing to engage in
customer transactions when there is
customer demand for those exposures at
commercially reasonable prices.
The following is an example of the
interplay between a trading desk’s
market-maker inventory and financial
exposure. An airline company customer
may seek to hedge its long-term
exposure to price fluctuations in jet fuel
by asking a banking entity to create a
structured ten-year, $1 billion jet fuel
893 The formation of structured finance products
and securitizations is discussed in detail in Part
IV.B.2.b. of this SUPPLEMENTARY INFORMATION.
894 See final rule § __.4(b)(2)(iii)(B), (C).
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swap for which there is no liquid
market. A trading desk that makes a
market in energy swaps may service its
customer’s needs by executing a custom
jet fuel swap with the customer and
holding the swap in its market-maker
inventory, if the resulting transaction
does not cause the trading desk to
exceed its market-maker inventory limit
on the applicable class of instrument, or
the trading desk has received approval
to increase the limit in accordance with
the authorization and escalation
procedures under paragraph
(b)(2)(iii)(E). In keeping with the marketmaking exemption as provided in the
final rule, the trading desk would be
required to hedge the risk from this
swap, either individually or as part of a
set of aggregated positions, if the trade
would result in a financial exposure that
exceeds the desk’s financial exposure
limits. The trading desk may hedge the
risk of the swap, for example, by
entering into one or more futures or
swap positions that are identified as
permissible hedging products,
instruments, or exposures in the trading
desk’s compliance program and that
analysis, including correlation analysis
as appropriate, indicates would
demonstrably reduce or otherwise
significantly mitigate risks associated
with the financial exposure from its
market-making activities. Alternatively,
if the trading desk also acts as a market
maker in crude oil futures, then the
desk’s exposures arising from its
market-making activities may naturally
hedge the jet fuel swap (i.e., it may
reduce its financial exposure levels
resulting from such instruments).895 The
trading desk must continue to
appropriately manage risks of its
financial exposure over time in
accordance with its financial exposure
limits.
As discussed above, several
commenters expressed concern that the
near-term customer demand
requirement is too restrictive and that it
could impede a market maker’s ability
to build or retain inventory, particularly
in less liquid markets where demand is
intermittent.896 Because customer
demand in illiquid markets can be
difficult to predict with precision,
market-maker inventory may not closely
track customer order flow. The Agencies
acknowledge that market makers will
face costs associated with demonstrating
that market-maker inventory is designed
not to exceed, on an ongoing basis, the
895 This natural hedge with futures would
introduce basis risk which, like other risks of the
trading desk, must be managed within the desk’s
limits.
896 See SIFMA (Asset Mgmt.) (Feb. 2012); T. Rowe
Price; CIEBA; ICI (Feb. 2012) RBC.
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reasonably expected near term demands
of customers, as required by the statute
and the final rule because this is an
analysis that banking entities may not
currently undertake. However, the final
rule includes certain modifications to
the proposed rule that are intended to
reduce the negative impacts cited by
commenters, such as limitations on
inventory management activity and
potential restrictions on market making
in less liquid instruments, which the
Agencies believe should reduce the
perceived burdens of the proposed near
term demand requirement. For example,
the final rule recognizes that liquidity,
maturity, and depth of the market vary
across asset classes. The Agencies
expect that the express recognition of
these differences in the rule should
avoid unduly impeding a market
maker’s ability to build or retain
inventory. More specifically, the
Agencies recognize the relationship
between market-maker inventory and
customer order flow can vary across
asset classes and that an inflexible
standard for demonstrating that
inventory does not exceed reasonably
expected near term demand could
provide an incentive to stop making
markets in illiquid asset classes.
i. Definition of ‘‘Client,’’ ‘‘Customer,’’
and ‘‘Counterparty’’
In response to comments requesting
further definition of the terms ‘‘client,’’
‘‘customer,’’ and ‘‘counterparty’’ for
purposes of this standard,897 the
Agencies have defined these terms in
the final rule. In particular, the final
rule defines ‘‘client,’’ ‘‘customer,’’ and
‘‘counterparty’’ as, on a collective or
individual basis, ‘‘market participants
that make use of the banking entity’s
market making-related services by
obtaining such services, responding to
quotations, or entering into a continuing
relationship with respect to such
services.’’ 898 However, for purposes of
the analysis supporting the marketmaker inventory held to meet the
reasonably expected near-term demands
of clients, customers and counterparties,
a client, customer, or counterparty of
the trading desk does not include a
trading desk or other organizational unit
of another entity if that entity has $50
billion or more in total trading assets
and liabilities, measured in accordance
with § ll.20(d)(1),899 unless the
897 See Japanese Bankers Ass’n.; Credit Suisse
(Seidel); Occupy; AFR et al. (Feb. 2012); Public
Citizen.
898 Final rule § ll.4(b)(3).
899 See final rule § ll.4(b)(3)(i). The Agencies
are using a $50 billion threshold for these purposes
in recognition that firms engaged in substantial
trading activity do not typically act as customers to
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trading desk documents how and why
such trading desk or other
organizational unit should be treated as
a customer or the transactions are
conducted anonymously on an
exchange or similar trading facility that
permits trading on behalf of a broad
range of market participants.900
The Agencies believe this definition is
generally consistent with the proposed
interpretation of ‘‘customer’’ in the
proposal. The proposal generally
provided that, for purposes of market
making on an exchange or other
organized trading facility, a customer is
any person on behalf of whom a buy or
sell order has been submitted. In the
context of the over-the-counter market,
a customer was generally considered to
be a market participant that makes use
of the market maker’s intermediation
services, either by requesting such
services or entering into a continuing
relationship for such services.901 The
definition of client, customer, and
counterparty in the final rule recognizes
that, in the context of market making in
a financial instrument that is executed
on an exchange or other organized
trading facility, a client, customer, or
counterparty would be any person
whose buy or sell order executes against
the banking entity’s quotation posted on
the exchange or other organized trading
facility.902 Under these circumstances,
the person would be trading with the
banking entity in response to the
banking entity’s quotations and
obtaining the banking entity’s market
making-related services. In the context
of market making in a financial
other market makers, while smaller regional firms
may Seek liquidity from larger firms as part of their
market making-related activities.
900 See final rule § ll.4(b)(3)(i)(A), (B). In
Appendix C of the proposed rule, a trading unit
engaged in market making-related activities would
have been required to describe how it identifies its
customers for purposes of the Customer-Facing
Trading Ratio, if applicable, including
documentation explaining when, how, and why a
broker-dealer, swap dealer, security-based swap
dealer, or any other entity engaged in market
making-related activities, or any affiliate thereof, is
considered to be a customer of the trading unit. See
Joint Proposal, 76 FR 68,964. While the proposed
approach would not have necessarily prevented any
of these entities from being considered a customer
of the trading desk, it would have required
enhanced documentation and justification for
treating any of these entities as a customer. The
final rule’s exclusion from the definition of client,
customer, and counterparty is similar to the
proposed approach, but is more narrowly focused
on firms that have $50 billion or more trading assets
and liabilities because, as noted above, the Agencies
believe firms engaged in such substantial trading
activity are less likely to act as customers to market
makers than smaller regional firms.
901 See Joint Proposal, 76 FR 68,960; CFTC
Proposal, 77 FR 8439.
902 See, e.g., Goldman (Prop. Trading) (explaining
generally how exchange-based market makers
operate).
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instrument in the OTC market, a client,
customer, or counterparty generally
would be a person that makes use of the
banking entity’s intermediation services,
either by requesting such services
(possibly via a request-for-quote on an
established trading facility) or entering
into a continuing relationship with the
banking entity with respect to such
services. For purposes of determining
the reasonably expected near-term
demands of customers, a client,
customer, or counterparty generally
would not include a trading desk or
other organizational unit of another
entity that has $50 billion or more in
total trading assets except if the trading
desk has a documented reason for
treating the trading desk or other
organizational unit of such entity as a
customer or the trading desk’s
transactions are executed anonymously
on an exchange or similar trading
facility that permits trading on behalf of
a broad range of market participants.
The Agencies believe that this exclusion
balances commenters’ suggested
alternatives of either defining as a
client, customer, or counterparty anyone
who is on the other side of a market
maker’s trade 903 or preventing any
banking entity from being a client,
customer, or counterparty.904 The
Agencies believe that the first
alternative is overly broad and would
not meaningfully distinguish between
permitted market making-related
activity and impermissible proprietary
trading. For example, the Agencies are
concerned that such an approach would
allow a trading desk to maintain an
outsized inventory and to justify such
inventory levels as being tangentially
related to expected market-wide
demand. On the other hand, preventing
any banking entity from being a client,
customer, or counterparty under the
final rule would result in an overly
narrow definition that would
significantly impact banking entities’
ability to provide and access market
making-related services. For example,
most banks look to market makers to
provide liquidity in connection with
their investment portfolios.
The Agencies further note that, with
respect to a banking entity that acts as
a primary dealer (or functional
equivalent) for a sovereign government,
the sovereign government and its central
bank are each a client, customer, or
903 See ISDA (Feb. 2012). In addition, a number
of commenters suggested that the rule should not
limit broker-dealers from being customers of a
market maker. See SIFMA et al. (Prop. Trading)
(Feb. 2012); Credit Suisse (Seidel); RBC; Comm. on
Capital Markets Regulation.
904 See AFR et al. (Feb. 2012); Occupy; Public
Citizen.
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5607
counterparty for purposes of the marketmaking exemption as well as the
underwriting exemption.905 The
Agencies believe this interpretation,
together with the modifications in the
rule that eliminate the requirement to
distinguish between revenues from
spreads and price appreciation and the
recognition that the market-making
exemption extends to market makingrelated activities appropriately captures
the unique relationship between a
primary dealer and the sovereign
government. Thus, generally a banking
entity may rely on the market-making
exemption for its activities as primary
dealer (or functional equivalent) to the
extent those activities are outside of the
underwriting exemption.906
For exchange-traded funds (‘‘ETFs’’)
(and related structures), Authorized
Participants (‘‘APs’’) are generally the
conduit for market participants seeking
to create or redeem shares of the fund
905 A primary dealer is a firm that trades a
sovereign government’s obligations directly with
the sovereign (in many cases, with the sovereign’s
central bank) as well as with other customers
through market making. The sovereign government
may impose conditions on a primary dealer or
require that it engage in certain trading in the
relevant government obligations (e.g., participate in
auctions for the government obligation or maintain
a liquid secondary market in the government
obligations). Further, a sovereign government may
limit the number of primary dealers that are
authorized to trade with the sovereign. A number
of countries use a primary dealer system, including
Australia, Brazil, Canada, China-Hong Kong,
France, Germany, Greece, India, Indonesia, Ireland,
Italy, Japan, Mexico, Netherlands, Portugal, South
Africa, South Korea, Spain, Turkey, the U.K., and
the U.S. See, e.g., Oliver Wyman (Feb. 2012). The
Agencies note that this standard would similarly
apply to the relationship between a banking entity
and a sovereign that does not have a formal primary
dealer system, provided the sovereign’s process
functions like a primary dealer framework.
906 See Goldman (Prop. Trading). See also supra
Part IV.A.3.c.2.b.ix. (discussing commenters’
concerns regarding primary dealer activity). Each
suggestion regarding the treatment of primary
dealer activity has not been incorporated into the
rule. Specifically, the exemption for market making
as applied to a primary dealer does not extend
without limitation to primary dealer activities that
are not conducted under the conditions of one of
the exemptions. These interpretations would be
inconsistent with Congressional intent for the
statute, to limit permissible market-making activity
through the statute’s near term demand requirement
and, thus, does not permit trading without
limitation. See SIFMA et al. (Prop. Trading) (Feb.
2012) (stating that permitted activities should
include trading necessary to meet the relevant
jurisdiction’s primary dealer and other
requirements); JPMC (indicating that the exemption
should cover all of a firm’s activities that are
necessary or reasonably incidental to its acting as
a primary dealer in a foreign government’s debt
securities); Goldman (Prop. Trading); Banco de
´
Mexico; IIB/EBF. Rather, recognizing that market
making by primary dealers is a key function, the
limits and other conditions of the rule are flexible
enough to permit necessary market making-related
activities.
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(or equivalent structure).907 For
example, an AP may buy ETF shares
from market participants who would
like to redeem those shares for cash or
a basket of instruments upon which the
ETF is based. To provide this service,
the AP may in turn redeem these shares
from the ETF itself. Similarly, an AP
may receive cash or financial
instruments from a market participant
seeking to purchase ETF shares, in
which case the AP may use that cash or
set of financial instruments to create
shares from the ETF. In either case, for
the purpose of the market-making
exemption, such market participants as
well as the ETF itself would be
considered clients, customers, or
counterparties of the AP.908 The
inventory of ETF shares or underlying
instruments held by the AP can
therefore be evaluated under the criteria
of the market-making exemption, such
as how these holdings relate to
reasonably expected near term customer
demand.909 These criteria can be
907 ETF sponsors enter into relationships with one
or more financial institutions that become APs for
the ETF. Only APs are permitted to purchase and
redeem shares directly from the ETF, and they can
do so only in large aggregations or blocks that are
commonly called ‘‘creation units.’’ In response to a
question in the proposal, a number of commenters
expressed concern that the proposed market-making
exemption may not permit certain AP and market
maker activities in ETFs and requested clarification
that these activities would be permitted under the
market-making exemption. See Joint Proposal, 76
FR 68,873 (question 91) (‘‘Do particular markets or
instruments, such as the market for exchange-traded
funds, raise particular issues that are not adequately
or appropriately addressed in the proposal? If so,
how could the proposal better address those
instruments, markets or market features?’’); CFTC
Proposal, 77 FR 8359 (question 91); supra Part
IV.A.3.c.2.b.vii. (discussing comments on this
issue).
908 This is consistent with two commenters’
request that an ETF issuer be considered a
‘‘counterparty’’ of the banking entity when it trades
directly with the ETF issuer as an AP. See ICI
Global; ICI (Feb. 2012). Further, this approach is
intended to address commenters’ concerns that the
near term demand requirement may limit a banking
entity’s ability to act as AP for an ETF. See BoA;
Vanguard. The Agencies believe that one
commenter’s concern about the impact of the
proposed source of revenue requirement on AP
activity should be addressed by the replacement of
this proposed requirement with a metric-based
focus on when a trading desk generates revenue
from its trading activity. See BoA; infra Part
IV.A.3.c.7.c. (discussing the new approach to
assessing a trading desk’s pattern of profit and loss).
909 This does not imply that the AP must perfectly
predict future customer demand, but rather that
there is a demonstrable, statistical, or historical
basis for the size of the inventory held, as more
fully discussed below. Consider, for example, a
fixed-income ETF with $500 million in assets. If, on
a typical day, an AP generates requests for $10 to
$20 million of creations or redemptions, then an
inventory of $10 to $20 million in bonds upon
which the ETF is based (or some small multiple
thereof) could be construed as consistent with
reasonably expected near term customer demand.
On the other hand, if under the same circumstances
an AP holds $1 billion of these bonds solely in its
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similarly applied to other activities of
the AP, such as building inventory to
‘‘seed’’ a new ETF or engaging in ETFloan related transactions.910 The
Agencies recognize that banking entities
currently conduct a substantial amount
of AP creation and redemption activity
in the ETF market and, thus, if the rule
were to prevent or restrict a banking
entity from acting as an AP for an ETF,
then the rule would impact the
functioning of the ETF market.911
Some firms, whether or not an AP in
a given ETF, may also actively engage in
buying and selling shares of an ETF and
its underlying instruments in the market
to maintain price continuity between
the ETF and its underlying instruments,
which are exchangeable for one another.
Sometimes these firms will register as
market makers on an exchange for a
given ETF, but other times they may not
register as market maker. Regardless of
whether or not the firm is registered as
a market maker on any given exchange,
this activity not only provides liquidity
for ETFs, but also, and very importantly,
helps keep the market price of an ETF
in line with the NAV of the fund. The
market-making exemption can be used
to evaluate trading that is intended to
maintain price continuity between these
exchangeable instruments by
considering how the firm quotes,
maintains risk and exposure limits,
manages its inventory and risk, and, in
the case of APs, exercises its ability to
create and redeem shares from the fund.
Because customers take positions in
capacity as an AP for this ETF, it would be more
difficult to justify this as needed for reasonably
expected near term customer demand and may be
indicative of an AP engaging in prohibited
proprietary trading.
910 In ETF loan transactions (also referred to as
‘‘create-to-lend’’ transactions), an AP borrows the
underlying instruments that form the creation
basket of an ETF, submits the borrowed instruments
to the ETF agent in exchange for a creation unit of
ETF shares, and lends the resulting ETF shares to
a customer that wants to borrow the ETF. At the
end of the ETF loan, the borrower returns the ETF
shares to the AP, and the AP redeems the ETF
shares with the ETF agent in exchange for the
underlying instruments that form the creation
basket. The AP may return the underlying
instruments to the parties from whom it borrowed
them or may use them for another loan, as long as
the AP is not obligated to return them at that time.
For the term of the ETF loan transaction, the AP
hedges against market risk arising from any
rebalancing of the ETF, which would change the
amount or type of underlying instruments the AP
would receive in exchange for the ETF compared
to the underlying instruments the AP borrowed and
submitted to the ETF agent to create the ETF shares.
See David J. Abner, The ETF Handbook, Ch. 12
(2010); Jean M. McLoughlin, Davis Polk & Wardwell
LLP, to Division of Corporation Finance, U.S.
Securities and Exchange Commission, dated Jan. 23,
2013, available at https://www.sec.gov/divisions/
corpfin/cf-noaction/2013/davis-polk-wardwell-llp012813–16a.pdf.
911 See SSgA (Feb. 2012).
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ETFs with an expectation that the price
relationship will be maintained, such
trading can be considered to be market
making-related activity.912
After considering comments, the
Agencies continue to take the view that
a trading desk would not qualify for the
market-making exemption if it is wholly
or principally engaged in arbitrage
trading or other trading that is not in
response to, or driven by, the demands
of clients, customers, or
counterparties.913 The Agencies believe
this activity, which is not in response to
or driven by customer demand, is
inconsistent with the Congressional
intent that market making-related
activity be designed not to exceed the
reasonably expected near term demands
of clients, customers, or counterparties.
For example, a trading desk would not
be permitted to engage in general
statistical arbitrage trading between
instruments that have some degree of
correlation but where neither
instrument has the capability of being
exchanged, converted, or exercised for
or into the other instrument. A trading
desk may, however, act as market maker
to a customer engaged in a statistical
arbitrage trading strategy. Furthermore
as suggested by some commenters,914
trading activity used by a market maker
to maintain a price relationship that is
expected and relied upon by clients,
customers, and counterparties is
permitted as it is related to the demands
of clients, customers, or counterparties
because the relevant instrument has the
capability of being exchanged,
912 A number of commenters expressed concern
that the proposed rule would limit market making
or AP activity in ETFs because market makers and
APs engage in trading to maintain a price
relationship between ETFs and their underlying
components, which promotes ETF market
efficiency. See Vanguard; RBC; Goldman (Prop.
Trading); JPMC; SIFMA et al. (Prop. Trading) (Feb.
2012); SSgA (Feb. 2012); Credit Suisse (Prop.
Trading).
913 Some commenters suggested that a range of
arbitrage trading should be permitted under the
market-making exemption. See, e.g., Goldman
(Prop. Trading); RBC; SIFMA et al. (Prop. Trading)
(Feb. 2012); JPMC. Other commenters, however,
stated that arbitrage trading should be prohibited
under the final rule. See AFR et al. (Feb. 2012);
Volcker; Occupy. In response to commenters
representing that it would be difficult to comply
with this standard because it requires a trading desk
to determine the proportionality of its activities in
response to customer demand compared to its
activities that are not in response to customer
demand, the Agencies believe that the statute
requires a banking entity to distinguish between
market making-related activities that are designed
not to exceed the reasonably expected near term
demands of customers and impermissible
proprietary trading. See Goldman (Prop. Trading);
RBC.
914 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); JPMC.
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converted, or exercised for or into
another instrument.915
The Agencies recognize that a trading
desk, in anticipating and responding to
customer needs, may engage in
interdealer trading as part of its
inventory management activities and
that interdealer trading provides certain
market benefits, such as more efficient
matching of customer order flow, greater
hedging options to reduce risk, and
enhanced ability to accumulate or exit
customer-related positions.916 The final
rule does not prohibit a trading desk
from using the market-making
exemption to engage in interdealer
trading that is consistent with and
related to facilitating permissible
trading with the trading desk’s clients,
customers, or counterparties.917
However, in determining the reasonably
expected near term demands of clients,
customers, or counterparties, a trading
desk generally may not account for the
expected trading interests of a trading
desk or other organizational unit of an
entity with aggregate trading assets and
liabilities of $50 billion or greater
(except if the trading desk documents
why and how a particular trading desk
or other organizational unit at such a
firm should be considered a customer or
the trading desk or conduct marketmaking activity anonymously on an
exchange or similar trading facility that
915 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); JPMC; Credit Suisse (Seidel). For example,
customers have an expectation of general price
alignment under these circumstances, both at the
time they decide to invest in the instrument and for
the remaining time they hold the instrument. To the
contrary, general statistical arbitrage does not
maintain a price relationship between related
instruments that is expected and relied upon by
customers and, thus, is not permitted under the
market-making exemption. Firms engage in general
statistical arbitrage to profit from differences in
market prices between instruments, assets, or price
or risk elements associated with instruments or
assets that are thought to be statistically related, but
which do not have a direct relationship of being
exchangeable, convertible, or exercisable for the
other.
916 See MetLife; ACLI (Feb. 2012); Goldman
(Prop. Trading); Morgan Stanley; Chamber (Feb.
2012); Prof. Duffie; Oliver Wyman (Dec. 2011);
Oliver Wyman (Feb. 2012).
917 A number of commenters requested that the
rule be modified to clearly recognize interdealer
trading as a component of permitted market
making-related activity. See MetLife; SIFMA et al.
(Prop. Trading) (Feb. 2012); RBC; Credit Suisse
(Seidel); JPMC; BoA; ACLI (Feb. 2012); AFR et al.
(Feb. 2012); ISDA (Feb. 2012); Goldman (Prop.
Trading); Oliver Wyman (Feb. 2012). One of these
commenters analyzed the potential market impact
of preventing interdealer trading, combined with
inventory limits. See Oliver Wyman (Feb. 2012).
Because the final rule does not prohibit interdealer
trading or limit inventory in the manner this
commenter assumed for purposes of its analysis, the
Agencies do not believe the final rule will have the
market impact cited by this commenter.
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permits trading on behalf of a broad
range of market participants).918
A trading desk may engage in
interdealer trading to: Establish or
acquire a position to meet the
reasonably expected near term demands
of its clients, customers, or
counterparties, including current
demand; unwind or sell positions
acquired from clients, customers, or
counterparties; or engage in riskmitigating or inventory management
transactions.919 The Agencies believe
that allowing a trading desk to continue
to engage in customer-related
interdealer trading is appropriate
because it can help a trading desk
appropriately manage its inventory and
risk levels and can effectively allow
clients, customers, or counterparties to
access a larger pool of liquidity. While
the Agencies recognize that effective
intermediation of client, customer, or
counterparty trading may require a
trading desk to engage in a certain
amount of interdealer trading, this is an
activity that will bear some scrutiny by
the Agencies and should be monitored
by banking entities to ensure it reflects
market-making activities and not
impermissible proprietary trading.
ii. Impact of the Liquidity, Maturity, and
Depth of the Market on the Analysis
Several commenters expressed
concern about the potential impact of
the proposed near term demand
requirement on market making in less
liquid markets and requested that the
Agencies recognize that near term
customer demand may vary across
different markets and asset classes.920
The Agencies understand that
reasonably expected near term customer
demand may vary based on the
liquidity, maturity, and depth of the
market for the relevant type of financial
instrument(s) in which the trading desk
918 See AFR et al. (Feb. 2012) (recognizing that
the ability to manage inventory through interdealer
transactions should be accommodated in the rule,
but recommending that this activity be conditioned
on a market maker having an appropriate level of
inventory after an interdealer transaction).
919 Provided it is consistent with the requirements
of the market-making exemption, including the near
term customer demand requirement, a trading desk
may trade for purposes of determining how to price
a financial instrument a customer Seeks to trade
with the trading desk or to determine the depth of
the market for a financial instrument a customer
Seeks to trade with the trading desk. See Goldman
(Prop. Trading).
920 See CIEBA (stating that, absent a different
interpretation for illiquid instruments, market
makers will err on the side of holding less inventory
to avoid sanctions for violating the rule); Morgan
Stanley; RBC; ICI (Feb. 2012) ISDA (Feb. 2012);
Comm. on Capital Markets Regulation; Alfred
Brock.
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5609
acts as market maker.921 As a result, the
final rule recognizes that these factors
impact the analysis of reasonably
expected near term demands of clients,
customers, or counterparties and the
amount, types, and risks of marketmaker inventory needed to meet such
demand.922 In particular, customer
demand is likely to be more frequent in
more liquid markets than in less liquid
or illiquid markets. As a result, market
makers in more liquid cash-based
markets, such as liquid equity
securities, should generally have higher
rates of inventory turnover and less aged
inventory than market makers in less
liquid or illiquid markets.923 Market
makers in less liquid cash-based
markets are more likely to hold a
particular position for a longer period of
time due to intermittent customer
demand. In the derivatives markets,
market makers carry open positions and
manage various risk factors, such as
exposure to different points on a yield
curve. These exposures are analogous to
inventory in the cash-based markets.
Further, it may be more difficult to
reasonably predict near term customer
demand in less mature markets due to,
among other things, a lack of historical
experience with client, customer, or
counterparty demands for the relevant
product. Under these circumstances, the
Agencies encourage banking entities to
consider their experience with similar
products or other relevant factors.924
iii. Demonstrable Analysis of Certain
Factors
In the proposal, the Agencies stated
that permitted market making includes
taking positions in securities in
anticipation of customer demand, so
long as any anticipatory buying or
921 See supra Part IV.A.3.c.2.b.ii. (discussing
comments on this issue).
922 See final rule § ll.4(b)(2)(ii)(A).
923 The final rule does not impose additional
capital requirements on aged inventory to
discourage a trading desk from retaining positions
in inventory, as suggested by some commenters. See
CalPERS; Vanguard. The Agencies believe the final
rule already limit a trading desk’s ability to hold
inventory over an extended period and do not See
a need at this time to include additional capital
requirements in the final rule. For example, a
trading desk must have written policies and
procedures relating to its inventory and must be
able to demonstrate, as needed, its analysis of why
the levels of its market-maker inventory are
necessary to meet, or is a result of meeting,
customer demand. See final rule § ll.4(b)(2)(ii),
(iii)(C).
924 The Agencies agree, as suggested by one
commenter, it may be appropriate for a market
maker in a new asset class or market to look to
reasonably expected future developments on the
basis of the trading desk’s customer relationships.
See Morgan Stanley. As discussed further below,
the Agencies recognize that a trading desk could
encounter similar issues if it is a new entrant in an
existing market.
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selling activity is reasonable and related
to clear, demonstrable trading interest of
clients, customers, or counterparties.925
A number of commenters expressed
concern about this proposed
interpretation’s impact on market
makers’ inventory management activity
and represented that it was inconsistent
with the statute’s near term demand
standard, which permits market-making
activity that is ‘‘designed’’ not to exceed
the ‘‘reasonably expected’’ near term
demands of customers.926 In response to
comments, the Agencies are permitting
a trading desk to take positions in
reasonable expectation of customer
demand in the near term based on a
demonstrable analysis that the amount,
types, and risks of the financial
instruments in the trading desk’s
market-maker inventory are designed
not to exceed, on an ongoing basis, the
reasonably expected near term demands
of customers.
The proposal also stated that a
banking entity’s determination of near
term customer demand should generally
be based on the unique customer base
of a specific market-making business
line (and not merely an expectation of
future price appreciation). Several
commenters stated that it was unclear
how such determinations should be
made and expressed concern that near
term customer demand cannot always
be accurately predicted,927 particularly
in markets where trades occur
infrequently and customer demand is
hard to predict 928 or when a banking
entity is entering a new market.929 To
address these comments, the Agencies
are providing additional information
about how a banking entity can comply
with the statute’s near term customer
demand requirement, including a new
requirement that a banking entity
conduct a demonstrable assessment of
reasonably expected near term customer
demand and several examples of factors
that may be relevant for conducting
such an assessment. The Agencies
believe it is important to require such
demonstrable analysis to allow
determinations of reasonably expected
near term demand and associated
inventory levels to be monitored and
925 See Joint Proposal, 76 FR 68,871; CFTC
Proposal, 77 FR 8356–8357.
926 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Goldman (Prop. Trading); Chamber (Feb.
2012); Comm. on Capital Markets Regulation. See
also Morgan Stanley; SIFMA (Asset Mgmt.) (Feb.
2012).
927 See SIFMA et al. (Prop. Trading) (Feb. 2012);
MetLife; Chamber (Feb. 2012); RBC; CIEBA;
Wellington; ICI (Feb. 2012) Alfred Brock.
928 See SIFMA et al. (Prop. Trading) (Feb. 2012).
929 See CIEBA.
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tested to ensure compliance with the
statute and the final rule.
The final rule provides that, to help
determine the appropriate amount,
types, and risks of the financial
instruments in the trading desk’s
market-maker inventory and to ensure
that such inventory is designed not to
exceed, on an ongoing basis, the
reasonably expected near term demands
of client, customers, or counterparties, a
banking entity must conduct
demonstrable analysis of historical
customer demand, current inventory of
financial instruments, and market and
other factors regarding the amount,
types, and risks of or associated with
financial instruments in which the
trading desk makes a market, including
through block trades. This analysis
should not be static or fixed solely on
current market or other factors. Instead,
an appropriately conducted analysis
under this provision will be both
backward- and forward-looking by
taking into account relevant historical
trends in customer demand 930 and any
events that are reasonably expected to
occur in the near term that would likely
impact demand.931 Depending on the
facts and circumstances, it may be
proper for a banking entity to weigh
these factors differently when
conducting an analysis under this
provision. For example, historical
trends in customer demand may be less
relevant when a trading desk is
experiencing or expects to experience a
change in the pattern of customer needs
(e.g., requests for block positioning),
adjustments to its business model (e.g.,
930 To determine an appropriate historical dataset,
a banking entity should assess the relation between
current or reasonably expected near term conditions
and demand and those of prior market cycles.
931 This analysis may, where appropriate, take
into account prior and/or anticipated cyclicality to
the demands of clients, customers, or
counterparties, which may cause variations in the
amounts, types, and risks of financial instruments
needed to provide intermediation services at
different points in a cycle. For example, the final
rule recognizes that a trading desk may need to
accumulate a larger-than-average amount of
inventory in anticipation of an index rebalance. See
supra note 838 (discussing a comment on this
issue). The Agencies are aware that a trading desk
engaged in block positioning activity may have a
less consistent pattern of inventory because of the
need to take on large block positions at the request
of customers. See supra note 761 and
accompanying text (discussing comments on this
issue).
Because the final rule does not prevent banking
entities from providing direct liquidity for
rebalance trades, the Agencies do not believe that
the final rule will cause the market impacts that one
commenter predicted would occur were such a
restriction adopted. See Oliver Wyman (Feb. 2012)
(estimating that if market makers are not able to
provide direct liquidity for rebalance trades,
investors tracking these indices could potentially
pay incremental costs of $600 million to $1.8
billion every year).
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efforts to expand or contract its market
shares), or changes in market
conditions.932 On the other hand, absent
these types of current or anticipated
events, the amount, types, and risks of
the financial instruments in the trading
desk’s market-maker inventory should
be relatively consistent with such
trading desk’s historical profile of
market-maker inventory.933
Moreover, the demonstrable analysis
required under § ll.4(b)(2)(ii)(B)
should account for, among other things,
how the market factors discussed in § l
l.4(b)(2)(ii)(A) impact the amount,
types, and risks of market-maker
inventory the trading desk may need to
facilitate reasonably expected near term
demands of clients, customers, or
counterparties.934 Other potential
factors that could be used to assess
reasonably expected near term customer
demand and the appropriate amount,
types, and risks of financial instruments
in the trading desk’s market-maker
inventory include, among others: (i)
Recent trading volumes and customer
trends; (ii) trading patterns of specific
customers or other observable customer
demand patterns; (iii) analysis of the
banking entity’s business plan and
ability to win new customer business;
(iv) evaluation of expected demand
under current market conditions
932 In addition, the Agencies recognize that a new
entrant to a particular market or asset class may not
have knowledge of historical customer demand in
that market or asset class at the outset. See supra
note 924 and accompanying text (discussing factors
that may be relevant to new market entrants for
purposes of determining the reasonably expected
near term demands of clients, customers, or
counterparties).
933 One commenter suggested an approach that
would allow market makers to build inventory in
products where they believe customer demand will
exist, regardless of whether inventory can be tied
to a particular customer in the near term or to
historical trends in customer demand. See Credit
Suisse (Seidel). The Agencies believe an approach
that does not provide for any consideration of
historical trends could result in a heightened risk
of evasion. At the same time, as discussed above,
the Agencies recognize that historical trends may
not always determine the amount of inventory a
trading desk may need to meet reasonably expected
near term demand and it may under certain
circumstances be appropriate to build inventory in
anticipation of a reasonably expected near term
event that would likely impact customer demand.
While the Agencies are not requiring that marketmaker inventory be tied to a particular customer,
The Agencies are requiring that a banking entity
analyze and support its expectations for near term
customer demand.
934 The Agencies recognize that a trading desk
could acquire either a long or short position in
reasonable anticipation of near term demands of
clients, customers, or counterparties. In particular,
if it is expected that customers will want to buy an
instrument in the near term, it may be appropriate
for the desk to acquire a long position in such
instrument. If it is expected that customers will
want to sell the instrument, acquiring a short
position may be appropriate under certain
circumstances.
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compared to prior similar periods; (v)
schedule of maturities in customers’
existing portfolios; and (vi) expected
market events, such as an index
rebalancing, and announcements. The
Agencies believe that some banking
entities already analyze these and other
relevant factors as part of their overall
risk management processes.935
With respect to the creation and
distribution of complex structured
products, a trading desk may be able to
use the market-making exemption to
acquire some or all of the risk exposures
associated with the product if the
trading desk has evidence of customer
demand for each of the significant risks
associated with the product.936 To have
evidence of customer demand under
these circumstances, there must be prior
express interest from customers in the
specific risk exposures of the product.
Without such express interest, a trading
desk would not have sufficient
information to support the required
demonstrable analysis (e.g., information
about historical customer demand or
other relevant factors).937 The Agencies
are concerned that, absent express
interest in each significant risk
associated with the product, a trading
desk could evade the market-making
exemption by structuring a deal with
certain risk exposures, or amounts of
risk exposures, for which there is no
customer demand and that would be
retained in the trading desk’s inventory,
potentially for speculative purposes.
Thus, a trading desk would not be
engaged in permitted market makingrelated activity if, for example, it
structured a product solely to acquire a
desired exposure and not to respond to
customer demand.938 When a trading
desk acquires risk exposures in these
circumstances, the trading desk would
be expected to enter into appropriate
hedging transactions or otherwise
mitigate the risks of these exposures,
consistent with its hedging policies and
procedures and risk limits.
With regard to a trading desk that
conducts its market-making activities on
an exchange or other similar anonymous
trading facility, the Agencies continue
to believe that market-making activities
are generally consistent with reasonably
expected near term customer demand
when such activities involve passively
providing liquidity by submitting
resting orders that interact with the
orders of others in a non-directional or
market-neutral trading strategy or by
regularly responding to requests for
quotes in markets where resting orders
are not generally provided. This ensures
that the trading desk has a pattern of
providing, rather than taking, liquidity.
However, this does not mean that a
trading desk acting as a market maker
on an exchange or other similar
anonymous trading facility is only
permitted to use these types of orders in
connection with its market makingrelated activities. The Agencies
recognize that it may be appropriate for
a trading desk to enter market or
marketable limit orders on an exchange
or other similar anonymous trading
facility, or to request quotes from other
market participants, in connection with
its market making-related activities for a
variety of purposes including, among
others, inventory management,
addressing order imbalances on an
exchange, and hedging.939 In response
to comments, the Agencies are not
requiring a banking entity to be
registered as a market maker on an
exchange or other similar anonymous
trading facility, if the exchange or other
similar anonymous trading facility
registers market makers, for purposes of
the final rule.940 The Agencies
935 See supra Part IV.A.3.c.2.b.iii. See FTN;
Morgan Stanley (suggesting a standard that would
require a position to be ‘‘reasonably consistent with
observable customer demand patterns’’).
936 Complex structured products can contain a
combination of several different types of risks,
including, among others, market risk, credit risk,
volatility risk, and prepayment risk.
937 In contrast, a trading desk may respond to
requests for customized transactions, such as
custom swaps, provided that the trading desk is a
market maker in the risk exposures underlying the
swap or can hedge the underlying risk exposures,
consistent with its financial exposure and hedging
limits, and otherwise meets the requirements of the
market-making exemption. For example, a trading
desk may routinely make markets in underlying
exposures and, thus, would meet the requirements
for engaging in transactions in derivatives that
reflect the same exposures. Alternatively, a trading
desk might meet the requirements by routinely
trading in the derivative and hedging in the
underlying exposures. See supra Part
IV.A.3.c.1.c.iii.
938 See, e.g., Sens. Merkley & Levin (Feb. 2012).
939 The Agencies are clarifying this point in
response to commenters who expressed concern
that the proposal would prevent an exchange
market maker from using market or marketable limit
orders under these circumstances. See, e.g., NYSE
Euronext; SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); RBC.
940 See supra notes 774 to 779 and accompanying
text (discussing commenters’ response to statements
in the proposal requiring exchange registration as
a market maker under certain circumstances).
Similarly, the final rule does not establish a
presumption of compliance with the market-making
exemption based on registration as a market maker
with an exchange, as requested by a few
commenters. See supra note 777 and accompanying
text. As noted above, activity that is considered
market making for purposes of this rule may not be
considered market making for purposes of other
rules, including self-regulatory organization rules,
and vice versa. In addition, exchange requirements
for registered market makers are subject to change
without consideration of the impact on this rule.
Although a banking entity is not required to be an
exchange-registered market maker under the final
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5611
recognize, as noted by commenters, that
there are a large number of exchanges
and organized trading facilities on
which market makers may need to trade
to maintain liquidity across the markets
and to provide customers with favorable
prices and that requiring registration
with each exchange or other trading
facility may unnecessarily restrict or
impose burdens on exchange marketmaking activities.941
A banking entity is not required to
conduct the demonstrable analysis
under § ll.4(b)(2)(B) of the final rule
on an instrument-by-instrument basis.
The Agencies recognize that, in certain
cases, customer demand may be for a
particular type of exposure, and a
customer may be willing to trade any
one of a number of instruments that
would provide the demanded exposure.
Thus, an assessment of the amount,
types, and risks of financial instruments
that the trading desk may hold in
market-maker inventory and that would
be designed not to exceed, on an
ongoing basis, the reasonably expected
near term demands of clients,
customers, or counterparties does not
need to be made for each financial
instrument in which the trading desk
acts as market maker. Instead, the
amount and types of financial
instruments in the trading desk’s
market-maker inventory should be
consistent with the types of financial
instruments in which the desk makes a
market and the amount and types of
such instruments that the desk’s
customers are reasonably expected to be
interested in trading.
In response to commenters’ concern
that banking entities may be subject to
regulatory sanctions if reasonably
expected customer demand does not
materialize,942 the Agencies recognize
that predicting the reasonably expected
near term demands of clients,
customers, or counterparties is
inherently subject to changes based on
market and other factors that are
difficult to predict with certainty. Thus,
there may at times be differences
between predicted demand and actual
demand from clients, customers, or
rule, a banking entity must be licensed or registered
to engage in market making-related activities in
accordance with applicable law. For example, a
banking entity would be required to be an SECregistered broker-dealer to engage in market
making-related activities in securities in the U.S.
unless the banking entity is exempt from
registration or excluded from regulation as a dealer
under the Exchange Act. See infra Part IV.A.3.c.6.;
final rule § ll.4(b)(2)(vi).
941 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading) (noting that there are more
than 12 exchanges and 40 alternative trading
systems currently trading U.S. equities).
942 See RBC; CIEBA; Wellington; ICI (Feb. 2012)
Invesco.
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counterparties. However, assessments of
expected near term demand may not be
reasonable if, in the aggregate and over
longer periods of time, a trading desk
exhibits a repeated pattern or practice of
significant variation in the amount,
types, and risks of financial instruments
in its market-maker inventory in excess
of what is needed to facilitate near term
customer demand.
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iv. Relationship to Required Limits
As discussed further below, a banking
entity must establish limits for each
trading desk on the amount, types, and
risks of its market-maker inventory,
level of exposures to relevant risk
factors arising from its financial
exposure, and period of time a financial
instrument may be held by a trading
desk. These limits must be reasonably
designed to ensure compliance with the
market-making exemption, including
the near term customer demand
requirement, and must take into account
the nature and amount of the trading
desk’s market making-related activities.
Thus, the limits should account for and
generally be consistent with the
historical near term demands of the
desk’s clients, customers, or
counterparties and the amount, types,
and risks of financial instruments that
the trading desk has historically held in
market-maker inventory to meet such
demands. In addition to the limits that
a trading desk selects in managing its
positions to ensure compliance with the
market-making exemption set out in
§ ll.4(b), the Agencies are requiring,
for banking entities that must report
metrics in Appendix A, such limits
include, at a minimum, ‘‘Risk Factor
Sensitivities’’ and ‘‘Value-at-Risk and
Stress Value-at-Risk’’ metrics as limits,
except to the extent any of the ‘‘Risk
Factor Sensitivities’’ or ‘‘Value-at-Risk
and Stress Value-at-Risk’’ metrics are
demonstrably ineffective for measuring
and monitoring the risks of a trading
desk based on the types of positions
traded by, and risk exposures of, that
desk.943 The Agencies believe that these
metrics can be useful for measuring and
managing many types of positions and
trading activities and therefore can be
useful in establishing a minimum set of
metrics for which limits should be
applied.944
As this requirement applies on an
ongoing basis, a trade in excess of one
943 See
Appendix A.
Agencies recognize that for some types of
positions or trading strategies, the use of ‘‘Risk
Factor Sensitivities’’ and ‘‘Value-at-Risk and Stress
Value-at-Risk’’ metrics may be ineffective and
accordingly limits do not need to be set for those
metrics if such ineffectiveness is demonstrated by
the banking entity.
944 The
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or more limits set for a trading desk
should not be permitted simply because
it responds to customer demand. Rather,
a banking entity’s compliance program
must include escalation procedures that
require review and approval of any
trade that would exceed one or more of
a trading desk’s limits, demonstrable
analysis that the basis for any temporary
or permanent increase to one or more of
a trading desk’s limits is consistent with
the requirements of this near term
demand requirement and with the
prudent management of risk by the
banking entity, and independent review
of such demonstrable analysis and
approval.945 The Agencies expect that a
trading desk’s escalation procedures
will generally explain the circumstances
under which a trading desk’s limits can
be increased, either temporarily or
permanently, and that such increases
must be consistent with reasonably
expected near term demands of the
desk’s clients, customers, or
counterparties and the amount and type
of risks to which the trading desk is
authorized to be exposed.
3. Compliance Program Requirement
a. Proposed Compliance Program
Requirement
To ensure that a banking entity
relying on the market-making
exemption had an appropriate
framework in place to support its
compliance with the exemption, § ll
.4(b)(2)(i) of the proposed rule required
a banking entity to establish an internal
compliance program, as required by
subpart D of the proposal, designed to
ensure compliance with the
requirements of the market-making
exemption.946
b. Comments on the Proposed
Compliance Program Requirement
A few commenters supported the
proposed requirement that a banking
entity establish a compliance program
under § ll.20 of the proposed rule as
effective.947 For example, one
commenter stated that the requirement
‘‘keeps a strong focus on the bank’s own
workings and allows banks to selfmonitor.’’ 948 One commenter indicated
that a comprehensive compliance
program is a ‘‘cornerstone of effective
corporate governance,’’ but cautioned
against placing ‘‘undue reliance’’ on
945 See final rule § ll.4(b)(2)(iii); infra Part
IV.A.3.c.3.c. (discussing the meaning of
‘‘independent’’ review for purposes of this
requirement).
946 See proposed rule § ll.4(b)(2)(i); Joint
Proposal, 76 FR 68,870; CFTC Proposal, 77 FR 8355.
947 See Flynn & Fusselman; Morgan Stanley.
948 See Flynn & Fusselman.
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compliance programs.949 As discussed
further below in Parts IV.C.1. and
IV.C.3., many commenters expressed
concern about the potential burdens of
the proposed rule’s compliance program
requirement, as well as the proposed
requirement regarding quantitative
measurements. According to one
commenter, the compliance burdens
associated with these requirements may
dissuade a banking entity from
attempting to comply with the marketmaking exemption.950
c. Final Compliance Program
Requirement
Similar to the proposed exemption,
the market-making exemption adopted
in the final rule requires that a banking
entity establish and implement,
maintain, and enforce an internal
compliance program required by
subpart D that is reasonably designed to
ensure the banking entity’s compliance
with the requirements of the marketmaking exemption, including
reasonably designed written policies
and procedures, internal controls,
analysis, and independent testing.951
This provision further requires that the
compliance program include particular
written policies and procedures,
internal controls, analysis, and
independent testing identifying and
addressing:
• The financial instruments each
trading desk stands ready to purchase
and sell as a market maker;
• The actions the trading desk will
take to demonstrably reduce or
otherwise significantly mitigate
promptly the risks of its financial
exposure consistent with the required
limits; the products, instruments, and
exposures each trading desk may use for
risk management purposes; the
techniques and strategies each trading
desk may use to manage the risks of its
market making-related activities and
inventory; and the process, strategies,
and personnel responsible for ensuring
that the actions taken by the trading
desk to mitigate these risks are and
continue to be effective;
• Limits for each trading desk, based
on the nature and amount of the trading
desk’s market making-related activities,
that address the factors prescribed by
the near term customer demand
requirement of the final rule, on:
Æ The amount, types, and risks of its
market-maker inventory;
949 See
Occupy.
ICI (Feb. 2012).
951 The independent testing standard is discussed
in more detail in Part IV.C., which discusses the
compliance program requirement in § ll.20 of the
final rule.
950 See
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Æ The amount, types, and risks of the
products, instruments, and exposures
the trading desk uses for risk
management purposes;
Æ Level of exposures to relevant risk
factors arising from its financial
exposure; and
Æ Period of time a financial
instrument may be held;
• Internal controls and ongoing
monitoring and analysis of each trading
desk’s compliance with its required
limits; and
• Authorization procedures,
including escalation procedures that
require review and approval of any
trade that would exceed a trading desk’s
limit(s), demonstrable analysis that the
basis for any temporary or permanent
increase to a trading desk’s limit(s) is
consistent with the requirements of
§ ll.4(b)(2)(ii) of the final rule, and
independent review (i.e., by risk
managers and compliance officers at the
appropriate level independent of the
trading desk) of such demonstrable
analysis and approval.952
The compliance program requirement
in the proposed market-making
exemption did not include specific
references to all the compliance
program elements now listed in the final
rule. Instead, these elements were
generally included in the compliance
requirements of Appendix C of the
proposed rule. The Agencies are moving
certain of these requirements into the
market-making exemption to ensure that
critical components are made part of the
compliance program for market makingrelated activities. Further, placing these
requirements within the market-making
exemption emphasizes the important
role they play in overall compliance
with the exemption.953 Banking entities
final rule § ll.4(b)(2)(iii).
Agencies note that a number of
commenters requested that the Agencies place a
greater emphasis on inventory limits and risk limits
in the final exemption. See, e.g., Citigroup
(suggesting that the market-making exemption
utilize risk limits that would be set for each trading
unit based on expected levels of customer trading—
estimated by looking to historical results, target
product and customer lists, and target market
share—and an appropriate amount of required
inventory to support that level of customer trading);
Prof. Colesanti et al. (suggesting that the exemption
include, among other things, a bright-line threshold
of the amount of risk that can be retained (which
cannot be in excess of the size and type required
for market making), positions limits, and limits on
holding periods); Sens. Merkley & Levin (Feb. 2012)
(suggesting the use of specific parameters for
inventory levels, along with a number of other
criteria, to establish a safe harbor); SIFMA et al.
(Prop. Trading) (Feb. 2012) (recommending the use
of risk limits in combination with a guidance-based
approach); Japanese Bankers Ass’n. (suggesting that
the rule set risk allowances for market makingrelated activities based on required capital for such
activities). The Agencies are not establishing
specific limits in the final rule, as some commenters
952 See
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953 The
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should note that these compliance
procedures must be established,
implemented, maintained, and enforced
for each trading desk engaged in market
making-related activities under the final
rule. Each of the requirements in
paragraphs (b)(2)(iii)(A) through (E)
must be appropriately tailored to the
individual trading activities and
strategies of each trading desk on an
ongoing basis.
As a threshold issue, the compliance
program must identify the products,
instruments, and exposures the trading
desk may trade as market maker or for
risk management purposes.954
Identifying the relevant instruments in
which a trading desk is permitted to
trade will facilitate monitoring and
oversight of compliance with the
exemption by preventing an individual
trader on a market-making desk from
establishing positions in instruments
that are unrelated to the desk’s marketmaking function. Further, this
identification of instruments helps form
the basis for the specific types of
inventory and risk limits that the
banking entity must establish and is
relevant to considerations throughout
the exemption regarding the liquidity,
depth, and maturity of the market for
the relevant type of financial
instrument. The Agencies note that a
banking entity should be able to
demonstrate the relationship between
the instruments in which a trading desk
may act as market maker and the
instruments the desk may use to manage
the risk of its market making-related
activities and inventory and why the
instruments the desk may use to manage
its risk appropriately and effectively
appeared to recommend, in recognition of the fact
that appropriate limits will differ based on a
number of factors, including the size of the marketmaking operation and the liquidity, depth, and
maturity of the market for the particular type(s) of
financial instruments in which the trading desk is
permitted to trade. See Sens. Merkley & Levin (Feb.
2012); Prof. Colesanti et al. However, banking
entities relying on the market-making exemption
must set limits and demonstrate how the specific
limits and limit methodologies they have chosen
are reasonably designed to limit the amount, types,
and risks of the financial instruments in a trading
desk’s market-maker inventory consistent with the
reasonably expected near term demands of the
banking entity’s clients, customers, and
counterparties, subject to the market and conditions
discussed above, and to commensurately control
the desk’s overall financial exposure.
954 See final rule § ll.4(b)(2)(iii)(A) (requiring
written policies and procedures, internal controls,
analysis, and independent testing regarding the
financial instruments each trading desk stands
ready to purchase and sell in accordance with § l
l.4(b)(2)(i) of the final rule); final rule § ll
.4(b)(2)(iii)(B) (requiring written policies and
procedures, internal controls, analysis, and
independent testing regarding the products,
instruments, or exposures each trading desk may
use for risk management purposes).
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mitigate the risk of its market makingrelated activities without generating an
entirely new set of risks that outweigh
the risks that are being hedged.
The final rule provides that a banking
entity must establish an appropriate risk
management framework for each of its
trading desks that rely on the marketmaking exemption.955 This includes not
only the techniques and strategies that
a trading desk may use to manage its
risk exposures, but also the actions the
trading desk will take to demonstrably
reduce or otherwise significantly
mitigate promptly the risks of its
financial exposures consistent with its
required limits, which are discussed in
more detail below. While the Agencies
do not expect a trading desk to hedge all
of the risks that arise from its market
making-related activities, the Agencies
do expect each trading desk to take
appropriate steps consistent with
market-making activities to contain and
limit risk exposures (such as by
unwinding unneeded positions) and to
follow reasonable procedures to monitor
the trading desk’s risk exposures (i.e., its
financial exposure) and hedge risks of
its financial exposure to remain within
its relevant risk limits.956
955 This standard addresses issues raised by
commenters concerning: Certain language in
proposed Appendix B regarding market makingrelated risk management; the market making-related
hedging provision in § ll.4(b)(3) of the proposed
rule; and, to some extent, the proposed source of
revenue requirement in § ll.4(b)(2)(v) of the
proposed rule. See Joint Proposal, 76 FR 68,960;
CFTC Proposal, 77 FR 8439–8440; proposed rule
§ ll.4(b)(3); Joint Proposal, 76 FR 68,873; CFTC
Proposal, 77 FR 8358; Wellington; Credit Suisse
(Seidel); Morgan Stanley; PUC Texas; CIEBA; SSgA
(Feb. 2012); Alliance Bernstein; Investure; Invesco;
Japanese Bankers Ass’n.; SIFMA et al. (Prop.
Trading) (Feb. 2012); FTN; RBC; NYSE Euronext;
MFA. As discussed in more detail above, a number
of commenters emphasized that market makingrelated activities necessarily involve a certain
amount of risk-taking to provide ‘‘immediacy’’ to
customers. See, e.g., Prof. Duffie; Morgan Stanley;
SIFMA et al. (Prop. Trading) (Feb. 2012).
Commenters also represented that the amount of
risk a market maker needs to retain may differ
across asset classes and markets. See, e.g., Morgan
Stanley; Credit Suisse (Seidel). The Agencies
believe that the requirement we are adopting better
recognizes that appropriate risk management will
tailor acceptable position, risk and inventory limits
based on the type(s) of financial instruments in
which the trading desk is permitted to trade and the
liquidity, maturity, and depth of the market for the
relevant type of financial instrument.
956 It may be more efficient for a banking entity
to manage some risks at a higher organizational
level than the trading desk level. As a result, a
banking entity’s written policies and procedures
may delegate the responsibility to mitigate specific
risks of the trading desk’s financial exposure to an
entity other than the trading desk, including
another organizational unit of the banking entity or
of an affiliate, provided that such organizational
unit of the banking entity or of an affiliate is
identified in the banking entity’s written policies
and procedures. Under these circumstances, the
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As discussed in Part IV.A.3.c.4.c.,
managing the risks associated with
maintaining a market-maker inventory
that is appropriate to meet the
reasonably expected near-term demands
of customers is an important part of
market making.957 The Agencies
understand that, in the context of
market-making activities, inventory
management includes adjustment of the
amount and types of market-maker
inventory to meet the reasonably
expected near term demands of
customers.958 Adjustments of the size
and types of a financial exposure are
also made to reduce or mitigate the risks
associated with financial instruments
held as part of a trading desk’s marketmaker inventory. A common strategy in
market making is to establish marketmaker inventory in anticipation of
reasonably expected customer needs
and then to reduce that market-maker
inventory over time as customer
demand materializes.959 If customer
demand does not materialize, the
market maker addresses the risks
associated with its market-maker
inventory by adjusting the amount or
types of financial instruments in its
inventory as well as taking steps
otherwise to mitigate the risk associated
with its inventory.
The Agencies recognize that, to
provide effective intermediation
services, a trading desk engaged in
permitted market making-related
activities retains a certain amount of
risk arising from the positions it holds
in inventory and may hedge certain
aspects of that risk. The requirements in
the final rule establish controls around
a trading desk’s risk management
activities, yet still recognize that a
trading desk engaged in market makingrelated activities may retain a certain
amount of risk in meeting the
reasonably expected near term demands
of clients, customers, or counterparties.
other organizational unit of the banking entity or of
an affiliate must conduct such hedging activity in
accordance with the requirements of the hedging
exemption in § ll.5 of the final rule, including
the documentation requirement in § ll.5(c). As
recognized in Part IV.A.4.d.4., hedging activity
conducted by a different organizational unit than
the unit responsible for the positions being hedged
presents a greater risk of evasion. Further, the risks
being managed by a higher organizational level than
the trading desk may be generated by trading desks
engaged in market making-related activity or by
trading desks engaged in other permitted activities.
Thus, it would be inappropriate for such hedging
activity to be conducted in reliance on the marketmaking exemption.
957 See supra Part IV.A.3.c.2.c. (discussing the
final near term demand requirement).
958 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Credit Suisse (Seidel); Goldman (Prop.
Trading); MFA; RBC.
959 See, e.g., BoA; SIFMA et al. (Prop. Trading)
(Feb. 2012); Chamber (Feb. 2012).
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As the Agencies noted in the proposal,
where the purpose of a transaction is to
hedge a market making-related position,
it would appear to be market makingrelated activity of the type described in
section 13(d)(1)(B) of the BHC Act.960
The Agencies emphasize that the only
risk management activities that qualify
for the market-making exemption—and
that are not subject to the hedging
exemption—are risk management
activities conducted or directed by the
trading desk in connection with its
market making-related activities and in
conformance with the trading desk’s
risk management policies and
procedures.961 A trading desk engaged
in market making-related activities
would be required to comply with the
hedging exemption or another available
exemption for any risk management or
other activity that is not in conformance
with the trading desk’s required marketmaking risk management policies and
procedures.
A banking entity’s written policies
and procedures, internal controls,
analysis, and independent testing
identifying and addressing the products,
instruments, or exposures and the
techniques and strategies that may be
used by each trading desk to manage the
risks of its market making-related
activities and inventory must cover both
how the trading desk may establish
hedges and how such hedges are
removed once the risk they were
mitigating is unwound. With respect to
establishing positions that hedge or
otherwise mitigate the risk(s) of market
making-related positions held by the
trading desk, the written policies and
procedures may consider the natural
hedging and diversification that occurs
960 See Joint Proposal, 76 FR 68,873; CFTC
Proposal, 77 FR 8358.
961 As discussed above, if a trading desk operating
under the market-making exemption directs a
different organizational unit of the banking entity
or an affiliate to establish a hedge position on the
desk’s behalf, then the other organizational unit
may rely on the market-making exemption to
establish the hedge position as long as: (i) The other
organizational unit’s hedging activity is consistent
with the trading desk’s risk management policies
and procedures (e.g., the hedge instrument,
technique, and strategy are consistent with those
identified in the trading desk’s policies and
procedures); and (ii) the hedge position is attributed
to the financial exposure of the trading desk and is
included in the trading desk’s daily profit and loss.
If a different organizational unit of the banking
entity or of an affiliate establishes a hedge for the
trading desk’s financial exposure based on its own
determination, or if such position was not
established in accordance with the trading desk’s
required procedures or was included in that other
organizational unit’s financial exposure and/or
daily profit and loss, then that hedge position must
be established in compliance with the hedging
exemption in § ll.5 of the rule, including the
documentation requirement in § ll.5(c). See
supra Part IV.A.3.c.1.c.ii.
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in an aggregation of long and short
positions in financial instruments for
which the trading desk is a market
maker,962 as it documents its specific
risk-mitigating strategies that use
instruments for which the desk is a
market maker or instruments for which
the desk is not a market maker. Further,
the written policies and procedures
identifying and addressing permissible
hedging techniques and strategies must
address the circumstances under which
the trading desk may be permitted to
engage in anticipatory hedging. Like the
proposed rule’s hedging exemption, a
trading desk may establish an
anticipatory hedge position before it
becomes exposed to a risk that it is
highly likely to become exposed to,
provided there is a sound risk
management rationale for establishing
such an anticipatory hedge position.963
For example, a trading desk may hedge
against specific positions promised to
customers, such as volume-weighted
average price (‘‘VWAP’’) orders or large
block trades, to facilitate the customer
trade.964 The amount of time that an
anticipatory hedge may precede the
establishment of the position to be
hedged will depend on market factors,
such as the liquidity of the hedging
position.
Written policies and procedures,
internal controls, analysis, and
independent testing established
pursuant to the final rule identifying
and addressing permissible hedging
techniques and strategies should be
designed to prevent a trading desk from
over-hedging its market-maker
inventory or financial exposure. Overhedging would occur if, for example, a
trading desk established a position in a
financial instrument for the purported
purpose of reducing a risk associated
with one or more market-making
positions when, in fact, that risk had
already been mitigated to the full extent
possible. Over-hedging results in a new
risk exposure that is unrelated to
market-making activities and, thus, is
not permitted under the market-making
exemption.
962 For example, this may occur if a U.S.
corporate bond trading desk acquires a $100 million
long position in the corporate bonds of one issuer
from clients, customers, or counterparties and
separately acquires a $50 million short position in
another issuer in the same market sector in
reasonable expectation of near term demand of
clients, customers, or counterparties. Although both
positions were acquired to facilitate customer
demand, the positions may also naturally hedge
each other, to some extent.
963 See Joint Proposal, 76 FR 68,875; CFTC
Proposal, 77 FR 8361.
964 Two commenters recommended that banking
entities be permitted to establish hedges prior to
acquiring the underlying risk exposure under these
circumstances. See Credit Suisse (Seidel); BoA.
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A trading desk’s financial exposure
generally would not be considered to be
consistent with market making-related
activities to the extent the trading desk
is engaged in hedging activities that are
inconsistent with the management of
identifiable risks in its market-maker
inventory or maintains significant hedge
positions after the underlying risk(s) of
the market-maker inventory have been
unwound. A banking entity’s written
policies and procedures, internal
controls, analysis, and independent
testing regarding the trading desk’s
permissible hedging techniques and
strategies must be designed to prevent a
trading desk from engaging in overhedging or maintaining hedge positions
after they are no longer needed.965
Further, the compliance program must
provide for the process and personnel
responsible for ensuring that the actions
taken by the trading desk to mitigate the
risks of its market making-related
activities are and continue to be
effective, which would include
monitoring for and addressing any
scenarios where a trading desk may be
engaged in over-hedging or maintaining
unnecessary hedge positions or new
significant risks have been introduced
by the hedging activity.
As a result of these limitations, the
size and risks of the trading desk’s
hedging positions are naturally
constrained by the size and risks of its
market-maker inventory, which must be
designed not to exceed the reasonably
expected near term demands of clients,
customers, or counterparties, as well as
by the risk limits and controls
established under the final rule. This
ultimately constrains a trading desk’s
overall financial exposure since such
position can only contain positions,
risks, and exposures related to the
market-maker inventory that are
designed to meet current or near term
customer demand and positions, risks
and exposures designed to mitigate the
risks in accordance with the limits
previously established for the trading
desk.
The written policies and procedures
identifying and addressing a trading
desk’s hedging techniques and strategies
also must describe how and under what
timeframe a trading desk must remove
hedge positions once the underlying
risk exposure is unwound. Similarly,
the compliance program established by
the banking entity to specify and control
the trading desk’s hedging activities in
accordance with the final rule must be
designed to prevent a trading desk from
purposefully or inadvertently
transforming its positions taken to
965 See
final rule § ll.4(b)(2)(iii)(B).
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manage the risk of its market-maker
inventory under the exemption into
what would otherwise be considered
prohibited proprietary trading.
Moreover, the compliance program
must provide for the process and
personnel responsible for ensuring that
the actions taken by the trading desk to
mitigate the risks of its market makingrelated activities and inventory—
including the instruments, techniques,
and strategies used for risk management
purposes—are and continue to be
effective. This includes ensuring that
hedges taken in the context of market
making-related activities continue to be
effective and that positions taken to
manage the risks of the trading desk’s
market-maker inventory are not
purposefully or inadvertently
transformed into what would otherwise
be considered prohibited proprietary
trading. If a banking entity’s monitoring
procedures find that a trading desk’s
risk management procedures are not
effective, such deficiencies must be
promptly escalated and remedied in
accordance with the banking entity’s
escalation procedures. A banking
entity’s written policies and procedures
must set forth the process for
determining the circumstances under
which a trading desk’s risk management
strategies may be modified. In addition,
risk management techniques and
strategies developed and used by a
trading desk must be independently
tested or verified by management
separate from the trading desk.
To control and limit the amount and
types of financial instruments and risks
that a trading desk may hold in
connection with its market makingrelated activities, a banking entity must
establish, implement, maintain, and
enforce reasonably designed written
policies and procedures, internal
controls, analysis, and independent
testing identifying and addressing
specific limits on a trading desk’s
market-maker inventory, risk
management positions, and financial
exposure. In particular, the compliance
program must establish limits for each
trading desk, based on the nature and
amount of its market making-related
activities (including the factors
prescribed by the near term customer
demand requirement), on the amount,
types, and risks of its market-maker
inventory, the amount, types, and risks
of the products, instruments, and
exposures the trading desk may use for
risk management purposes, the level of
exposures to relevant risk factors arising
from its financial exposure, and the
period of time a financial instrument
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5615
may be held.966 The limits would be set,
as appropriate, and supported by an
analysis for specific types of financial
instruments, levels of risk, and duration
of holdings, which would also be
required by the compliance appendix.
This approach will build on existing
risk management infrastructure for
market-making activities that subject
traders to a variety of internal,
predefined limits.967 Each of these
limits is independent of the others, and
a trading desk must maintain its
aggregated market-making position
within each of these limits, including by
taking action to bring the trading desk
into compliance with the limits as
promptly as possible after the limit is
exceeded.968 For example, if changing
market conditions cause an increase in
one or more risks within the trading
desk’s financial exposure and that
increased risk causes the desk to exceed
one or more of its limits, the trading
desk must take prompt action to reduce
its risk exposure (either by hedging the
risk or unwinding its existing positions)
or receive approval of a temporary or
permanent increase to its limit through
the required escalation procedures.
The Agencies recognize that trading
desks’ limits will differ across asset
classes and acknowledge that trading
desks engaged in market making-related
activities in less liquid asset classes,
such as corporate bonds, certain
derivatives, and securitized products,
may require different inventory, risk
exposure, and holding period limits
than trading desks engaged in market
making-related activities in more liquid
financial instruments, such as certain
listed equity securities. Moreover, the
types of risk factors for which limits are
established should not be limited solely
to market risk factors. Instead, such
limits should also account for all risk
factors that arise from the types of
financial instruments in which the
trading desk is permitted to trade. In
addition, these limits should be
sufficiently granular and focused on the
particular types of financial instruments
in which the desk may trade. For
example, a trading desk that makes a
market in derivatives would have
exposures to counterparty risk, among
others, and would need to have
appropriate limits on such risk. Other
types of limits that may be relevant for
a trading desk include, among others,
final rule § ll.4(b)(2)(iii)(C).
e.g., Citigroup (Feb. 2012) (noting that its
suggested approach to implementing the marketmaking exemption, which would focus on risk
limits and risk architecture, would build on existing
risk limits and risk management systems already
present in institutions).
968 See final rule § ll.4(b)(2)(iv).
966 See
967 See,
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position limits, sector limits, and
geographic limits.
A banking entity must have a
reasonable basis for the limits it
establishes for a trading desk and must
have a robust procedure for analyzing,
establishing, and monitoring limits, as
well as appropriate escalation
procedures.969 Among other things, the
banking entity’s compliance program
must provide for: (i) Written policies
and procedures and internal controls
establishing and monitoring specific
limits for each trading desk; and (ii)
analysis regarding how and why these
limits are determined to be appropriate
and consistent with the nature and
amount of the desk’s market makingrelated activities, including
considerations related to the near term
customer demand requirement. In
making these determinations, a banking
entity should take into account and be
consistent with the type(s) of financial
instruments the desk is permitted to
trade, the desk’s trading and risk
management activities and strategies,
the history and experience of the desk,
and the historical profile of the desk’s
near term customer demand and market
and other factors that may impact the
reasonably expected near term demands
of customers.
The limits established by a banking
entity should generally reflect the
amount and types of inventory and risk
that a trading desk holds to meet the
reasonably expected near term demands
of clients, customers, or counterparties.
As discussed above, while the trading
desk’s market-maker inventory is
directly limited by the reasonably
expected near term demands of
customers, the positions managed by the
trading desk outside of its market-maker
inventory are similarly constrained by
the near term demand requirement
because they must be designed to
manage the risks of the market-maker
inventory in accordance with the desk’s
risk management procedures. As a
result, the trading desk’s risk
management positions and aggregate
financial exposure are also limited by
the current and reasonably expected
near term demands of customers. A
trading desk’s market-maker inventory,
risk management positions, or financial
exposure would not, however, be
permissible under the market-making
exemption merely because the marketmaker inventory, risk management
positions, or financial exposure happens
to be within the desk’s prescribed
limits.970
final rule § ll.4(b)(2)(iii)(C).
example, if a U.S. corporate bond trading
desk has a prescribed limit of $200 million net
969 See
970 For
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In addition, a banking entity must
establish internal controls and ongoing
monitoring and analysis of each trading
desk’s compliance with its limits,
including the frequency, nature, and
extent of a trading desk exceeding its
limits and patterns regarding the
portions of the trading desk’s limits that
are accounted for by the trading desk’s
activity.971 This may include the use of
management and exception reports.
Moreover, the compliance program must
set forth a process for determining the
circumstances under which a trading
desk’s limits may be modified on a
temporary or permanent basis (e.g., due
to market changes or modifications to
the trading desk’s strategy).972 This
process must cover potential scenarios
when a trading desk’s limits should be
raised, as well as potential scenarios
when a trading desk’s limits should be
lowered. For example, if a trading desk
experiences reduced customer demand
over a period of time, that trading desk’s
limits should be decreased to address
the factors prescribed by the near term
demand requirement.
A banking entity’s compliance
program must also include escalation
procedures that require review and
approval of any trade that would exceed
one or more of a trading desk’s limits,
demonstrable analysis that the basis for
any temporary or permanent increase to
one or more of a trading desk’s limits is
consistent with the near term customer
demand requirement, and independent
review of such demonstrable analysis
and approval of any increase to one or
more of a trading desk’s limits.973 Thus,
in order to increase a limit of a trading
exposure to any single sector of related issuers, the
desk’s limits may permit it to acquire a net
economic exposure of $400 million long to issuer
ABC and a net economic exposure of $300 million
short to issuer XYZ, where ABC and XYZ are in the
same sector. This is because the trading desk’s net
exposure to the sector would only be $100 million,
which is within its limits. Even though the net
exposure to this sector is within the trading desk’s
prescribed limits, the desk would still need to be
able to demonstrate how its net exposure of $400
million long to issuer ABC and $300 million short
to issuer XYZ is related to customer demand.
971 See final rule § ll.4(b)(2)(iii)(D).
972 For example, a banking entity may determine
to permit temporary, short-term increases to a
trading desk’s risk limits due to an increase in
short-term credit spreads or in response to volatility
in instruments in which the trading desk makes a
market, provided the increased limit is consistent
with the reasonably expected near term demands of
clients, customers, or counterparties. As noted
above, other potential circumstances that could
warrant changes to a trading desk’s limits include:
A change in the pattern of customer needs,
adjustments to the market maker’s business model
(e.g., new entrants or existing market makers trying
to expand or contract their market share), or
changes in market conditions. See supra note 932
and accompanying text.
973 See final rule § ll.4(b)(2)(iii)(E).
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desk—on either a temporary or
permanent basis—there must be an
analysis of why such increase would be
appropriate based on the reasonably
expected near term demands of clients,
customers, or counterparties, including
the factors identified in § ll.4(b)(2)(ii)
of the final rule, which must be
independently reviewed. A banking
entity also must maintain
documentation and records with respect
to these elements, consistent with the
requirement of § ll.20(b)(6).
As already discussed, commenters
have represented that the compliance
costs associated with the proposed rule,
including the compliance program and
metrics requirements, may be significant
and ‘‘may dissuade a banking entity
from attempting to comply with the
market making-related activities
exemption.’’974 The Agencies believe
that a robust compliance program is
necessary to ensure adherence to the
rule and to prevent evasion, although, as
discussed in Part IV.C.3., the Agencies
are adopting a more tailored set of
quantitative measurements to better
focus on those that are most germane to
evaluating market making-related
activity. The Agencies acknowledge that
the compliance program requirements
for the market-making exemption,
including reasonably designed written
policies and procedures, internal
controls, analysis, and independent
testing, represent a new regulatory
requirement for banking entities and the
Agencies have thus been mindful that it
may impose significant costs and may
cause a banking entity to reconsider
whether to conduct market makingrelated activities. Despite the potential
costs of the compliance program, the
Agencies believe they are warranted to
ensure that the goals of the rule and
statute will be met, such as promoting
the safety and soundness of banking
entities and the financial stability of the
United States.
4. Market Making-Related Hedging
a. Proposed Treatment of Market
Making-Related Hedging
In the proposal, certain hedging
transactions related to market making
were considered to be made in
connection with a banking entity’s
market making-related activity for
purposes of the market-making
exemption. The Agencies explained that
where the purpose of a transaction is to
hedge a market making-related position,
it would appear to be market makingrelated activity of the type described in
974 See
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section 13(d)(1)(B) of the BHC Act.975
To qualify for the market-making
exemption, a hedging transaction would
have been required to meet certain
requirements under § ll.4(b)(3) of the
proposed rule. This provision required
that the purchase or sale of a financial
instrument: (i) Be conducted to reduce
the specific risks to the banking entity
in connection with and related to
individual or aggregated positions,
contracts, or other holdings acquired
pursuant to the market-making
exemption; and (ii) meet the criteria
specified in § ll.5(b) of the proposed
hedging exemption and, where
applicable, § ll.5(c) of the
proposal.976 In the proposal, the
Agencies noted that a market maker may
often make a market in one type of
financial instrument and hedge its
activities using different financial
instruments in which it does not make
a market. The Agencies stated that this
type of hedging transaction would meet
the terms of the market-making
exemption if the hedging transaction
met the requirements of
§ ll.4(b)(3) of the proposed rule.977
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b. Comments on the Proposed
Treatment of Market Making-Related
Hedging
Several commenters recommended
that the proposed market-making
exemption be modified to establish a
more permissive standard for market
maker hedging.978 A few of these
commenters stated that, rather than
applying the standards of the riskmitigating hedging exemption to market
maker hedging, a market maker’s hedge
position should be permitted as long as
it is designed to mitigate the risk
associated with positions acquired
through permitted market makingrelated activities.979 Other commenters
emphasized the need for flexibility to
permit a market maker to choose the
most effective hedge.980 In general,
these commenters expressed concern
that limitations on hedging market
975 See Joint Proposal, 76 FR 68,873; CFTC
Proposal, 77 FR 8358.
976 See proposed rule § ll.4(b)(3); Joint
Proposal, 76 FR 68,873; CFTC Proposal, 77 FR 8358.
977 See Joint Proposal, 76 FR 68,870 n.146; CFTC
Proposal, 77 FR 8356 n.152.
978 See, e.g., Japanese Bankers Ass’n.; SIFMA et
al. (Prop. Trading) (Feb. 2012); Credit Suisse
(Seidel); FTN; RBC; NYSE Euronext; MFA. These
comments are addressed in Part IV.A.3.c.4.c., infra.
979 See SIFMA et al. (Prop. Trading) (Feb. 2012);
RBC. See also FTN (stating that the principal
requirement for such hedges should be that they
reduce the risk of market making).
980 See NYSE Euronext (stating that the best
hedge sometimes involves a variety of complex and
dynamic transactions over the time in which an
asset is held, which may fall outside the parameters
of the exemption); MFA; JPMC.
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making-related positions may cause a
reduction in liquidity, wider spreads, or
increased risk and trading costs for
market makers.981 For example, one
commenter stated that ‘‘[t]he ability of
market makers to freely offset or hedge
positions is what, in most cases, makes
them willing to buy and sell [financial
instruments] to and from customers,
clients or counterparties,’’ so ‘‘[a]ny
impediment to hedging market makingrelated positions will decrease the
willingness of banking entities to make
markets and, accordingly, reduce
liquidity in the marketplace.’’ 982
In addition, some commenters
expressed concern that certain
requirements in the proposed hedging
exemption may result in a reduction in
market-making activities under certain
circumstances.983 For example, one
commenter expressed concern that the
proposed hedging exemption would
require a banking entity to identify and
tag hedging transactions when hedges in
a particular asset class take place
alongside a trading desk’s customer flow
trading and inventory management in
that same asset class.984 Further, a few
commenters represented that the
proposed reasonable correlation
requirement in the hedging exemption
could impact market making by
discouraging market makers from
entering into customer transactions that
do not have a direct hedge 985 or making
it more difficult for market makers to
cost-effectively hedge the fixed income
securities they hold in inventory,
including hedging such inventory
positions on a portfolio basis.986
One commenter, however, stated that
the proposed approach is effective.987
Another commenter indicated that it is
confusing to include hedging within the
market-making exemption and
suggested that a market maker be
required to rely on the hedging
exemption under § ll.5 of the
proposed rule for its hedging activity.988
As noted above in the discussion of
comments on the proposed source of
revenue requirement, a number of
commenters expressed concern that the
proposed rule assumed that there are
effective, or perfect, hedges for all
market making-related positions.989
981 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); NYSE Euronext; MFA;
Japanese Bankers Ass’n.; RBC.
982 RBC.
983 See BoA; SIFMA (Asset Mgmt.) (Feb. 2012).
984 See Goldman (Prop. Trading).
985 See BoA.
986 See SIFMA (Asset Mgmt.) (Feb. 2012).
987 See Alfred Brock.
988 See Occupy.
989 See infra notes 1068 to 1070 and
accompanying text.
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5617
Another commenter stated that market
makers should be required to hedge
whenever an inventory imbalance
arises, and the absence of a hedge in
such circumstances may evidence
prohibited proprietary trading.990
c. Treatment of Market Making-Related
Hedging in the Final Rule
Unlike the proposed rule, the final
rule does not require that market
making-related hedging activities
separately comply with the
requirements found in the riskmitigating hedging exemption if
conducted or directed by the same
trading desk conducting the marketmaking activity. Instead, the Agencies
are including requirements for market
making-related hedging activities within
the market-making exemption in
response to comments.991 As discussed
above, a trading desk’s compliance
program must include written policies
and procedures, internal controls,
independent testing and analysis
identifying and addressing the products,
instruments, exposures, techniques, and
strategies a trading desk may use to
manage the risks of its market makingrelated activities, as well as the actions
the trading desk will take to
demonstrably reduce or otherwise
significant mitigate the risks of its
financial exposure consistent with its
required limits.992 The Agencies believe
this approach addresses commenters’
concerns that limitations on hedging
market making-related positions may
cause a reduction in liquidity, wider
spreads, or increased risk and trading
costs for market makers because it
allows banking entities to determine
how best to manage the risks of trading
desks’ market making-related activities
through reasonable policies and
procedures, internal controls,
independent testing, and analysis,
rather than requiring compliance with
the specific requirements of the hedging
exemption.993 Further, this approach
addresses commenters’ concerns about
the impact of certain requirements of
the hedging exemption on market
making-related activities.994
The Agencies believe it is consistent
with the statute’s reference to ‘‘market
making-related’’ activities to permit
990 See
Public Citizen.
e.g., Japanese Bankers Ass’n.; SIFMA et
al. (Prop. Trading) (Feb. 2012); Credit Suisse
(Seidel); FTN; RBC; NYSE Euronext; MFA.
992 See final rule § ll.4(b)(2)(iii)(B); supra Part
IV.A.3.c.3.c.
993 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); NYSE Euronext; MFA;
Japanese Bankers Ass’n.; RBC.
994 See BoA; SIFMA (Asset Mgmt.) (Feb. 2012);
Goldman (Prop. Trading).
991 See,
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market making-related hedging
activities under this exemption. In
addition, the Agencies believe it is
appropriate to require a trading desk to
appropriately manage its risks,
consistent with its risk management
procedures and limits, because
management of risk is a key factor that
distinguishes permitted market makingrelated activity from impermissible
proprietary trading. As noted in the
proposal, while ‘‘a market maker
attempts to eliminate some [of the risks
arising from] its retained principal
positions and risks by hedging or
otherwise managing those risks [ ], a
proprietary trader seeks to capitalize on
those risks, and generally only hedges or
manages a portion of those risks when
doing so would improve the potential
profitability of the risk it retains.’’ 995
The Agencies recognize that some
banking entities may manage the risks
associated with market making at a
different level than the individual
trading desk.996 While this risk
management activity is not permitted
under the market-making exemption, it
may be permitted under the hedging
exemption, provided the requirements
of that exemption are met. Thus, the
Agencies believe banking entities will
continue to have options available that
allow them to efficiently hedge the risks
arising from their market-making
operations. Nevertheless, the Agencies
understand that this rule will result in
additional documentation or other
potential burdens for market makingrelated hedging activity that is not
conducted by the trading desk
responsible for the market-making
positions being hedged.997 As discussed
in Part IV.A.4.d.4., hedging conducted
by a different organizational unit than
the trading desk that is responsible for
the underlying positions presents an
increased risk of evasion, so the
Agencies believe it is appropriate for
such hedging activity to be required to
comply with the hedging exemption,
including the associated documentation
requirement.
5. Compensation Requirement
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a. Proposed Compensation Requirement
Section ll.4(b)(2)(vii) of the
proposed market-making exemption
would have required that the
compensation arrangements of persons
995 See
Joint Proposal, 76 FR 68,961.
e.g., letter from JPMC (stating that, to
minimize risk management costs, firms commonly
organize their market-making activities so that risks
delivered to client-facing desks are aggregated and
passed by means of internal transactions to a single
utility desk and suggesting this be recognized as
permitted market making-related behavior).
997 See final rule § ll.5(c).
996 See,
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performing market making-related
activities at the banking entity be
designed not to reward proprietary risktaking.998 In the proposal, the Agencies
noted that activities for which a banking
entity has established a compensation
incentive structure that rewards
speculation in, and appreciation of, the
market value of a financial instrument
position held in inventory, rather than
success in providing effective and
timely intermediation and liquidity
services to customers, would be
inconsistent with the proposed marketmaking exemption.
The Agencies stated that under the
proposed rule, a banking entity relying
on the market-making exemption should
provide compensation incentives that
primarily reward customer revenues
and effective customer service, not
proprietary risk-taking. However, the
Agencies noted that a banking entity
relying on the proposed market-making
exemption would be able to
appropriately take into account
revenues resulting from movements in
the price of principal positions to the
extent that such revenues reflect the
effectiveness with which personnel
have managed principal risk retained.999
b. Comments Regarding the Proposed
Compensation Requirement
Several commenters recommended
certain revisions to the proposed
compensation requirement.1000 Two
commenters stated that the proposed
requirement is effective,1001 while one
commenter stated that it should be
removed from the rule.1002 Moreover, in
addressing this proposed requirement,
commenters provided views on:
identifiable characteristics of
compensation arrangements that
incentivize prohibited proprietary
trading,1003 methods of monitoring
compliance with this requirement,1004
and potential negative incentives or
outcomes this requirement could
cause.1005
With respect to suggested
modifications to this requirement, a few
commenters suggested that a market
maker’s compensation should be subject
proposed rule § ll.4(b)(2)(vii).
Joint Proposal, 76 FR 68,872; CFTC
Proposal, 77 FR 8358.
1000 See Prof. Duffie; SIFMA et al. (Prop. Trading)
(Feb. 2012); John Reed; Credit Suisse (Seidel);
JPMC; Morgan Stanley; Better Markets (Feb. 2012);
Johnson & Prof. Stiglitz; Occupy; AFR et al. (Feb.
2012); Public Citizen.
1001 See FTN; Alfred Brock.
1002 See Japanese Bankers Ass’n.
1003 See Occupy.
1004 See Occupy; Goldman (Prop. Trading).
1005 See AllianceBernstein; Prof. Duffie; Investure;
STANY; Chamber (Dec. 2011).
998 See
999 See
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to additional limitations.1006 For
example, two commenters stated that
compensation should be restricted to
particular sources, such as fees,
commissions, and spreads.1007 One
commenter suggested that compensation
should not be symmetrical between
gains and losses and, further, that
trading gains reflecting an unusually
high variance in position values should
either not be reflected in compensation
and bonuses or should be less reflected
than other gains and losses.1008 Another
commenter recommended that the
Agencies remove ‘‘designed’’ from the
rule text and provide greater clarity
about how a banking entity’s
compensation regime must be
structured.1009 Moreover, a number of
commenters stated that compensation
should be vested for a period of time,
such as until the trader’s market making
positions have been fully unwound and
are no longer in the banking entity’s
inventory.1010 As one commenter
explained, such a requirement would
discourage traders from carrying
inventory and encourage them to get out
of positions as soon as possible.1011
Some commenters also recommended
that compensation be risk adjusted.1012
A few commenters indicated that the
proposed approach may be too
restrictive.1013 Two of these commenters
stated that the compensation
requirement should instead be set forth
as guidance in Appendix B.1014 In
addition, two commenters requested
that the Agencies clarify that
compensation arrangements must be
designed not to reward prohibited
proprietary risk-taking. These
commenters were concerned the
proposed approach may restrict a
banking entity’s ability to provide
compensation for permitted activities,
1006 See Better Markets (Feb. 2012); Public
Citizen; AFR et al. (Feb. 2012); Occupy; John Reed;
AFR et al. (Feb. 2012); Johnson & Prof. Stiglitz; Prof.
Duffie; Sens. Merkley & Levin (Feb. 2012). These
comments are addressed in note 1027, infra.
1007 See Better Markets (Feb. 2012); Public
Citizen.
1008 See AFR et al. (Feb. 2012)
1009 See Occupy.
1010 See John Reed; AFR et al. (Feb. 2012);
Johnson & Prof. Stiglitz; Prof. Duffie (‘‘A trader’s
incentives for risk taking can be held in check by
vesting incentive-based compensation over a
substantial period of time. Pending compensation
can thus be forfeited if a trader’s negligence causes
substantial losses or if his or her employer fails.’’);
Sens. Merkley & Levin (Feb. 2012).
1011 See John Reed.
1012 See Johnson & Prof. Stiglitz; John Reed; Sens.
Merkley & Levin (Feb. 2012).
1013 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; Morgan Stanley.
1014 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC.
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which also involve proprietary
trading.1015
Two commenters discussed
identifiable characteristics of
compensation arrangements that clearly
incentivize prohibited proprietary
trading.1016 For example, one
commenter stated that rewarding pure
profit and loss, without consideration
for the risk that was assumed to capture
it, is an identifiable characteristic of an
arrangement that incentivizes
proprietary risk-taking.1017 For purposes
of monitoring and ensuring compliance
with this requirement, one commenter
noted that existing Board regulations for
systemically important banking entities
require comprehensive firm-wide
policies that determine compensation.
This commenter stated that those
regulations, along with appropriately
calibrated metrics, should ensure that
compensation arrangements are not
designed to reward prohibited
proprietary risk-taking.1018 For similar
purposes, another commenter suggested
that compensation incentives should be
based on a metric that meaningfully
accounts for the risk underlying
profitability.1019
Certain commenters expressed
concern that the proposed
compensation requirement could
incentivize market makers to act in a
way that would not be beneficial to
customers or market liquidity.1020 For
example, two commenters expressed
concern that the requirement could
cause market makers to widen their
spreads or charge higher fees because
their personal compensation depends
on these factors.1021 One commenter
stated that the proposed requirement
could dampen traders’ incentives and
discretion and may make market makers
less likely to accept trades involving
significant increases in risk or profit.1022
Another commenter expressed the view
that profitability-based compensation
arrangements encourage traders to
exercise due care because such
arrangements create incentives to avoid
losses.1023 Finally, one commenter
stated that compliance with the
proposed requirement may be difficult
or impossible if the Agencies do not
1015 See Morgan Stanley; SIFMA et al. (Prop.
Trading) (Feb. 2012). The Agencies respond to these
comments in note 1026 and its accompanying text,
infra.
1016 See Occupy; Alfred Brock.
1017 See Occupy. The Agencies respond to this
comment in Part IV.A.3.c.5.c., infra.
1018 See Goldman (Prop. Trading).
1019 See Occupy.
1020 See AllianceBernstein; Investure; Prof. Duffie;
STANY. This issue is addressed in note 1027, infra.
1021 See AllianceBernstein; Investure.
1022 See Prof. Duffie.
1023 See STANY.
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take into account the incentive-based
compensation rulemaking.1024
c. Final Compensation Requirement
Similar to the proposed rule, the
market-making exemption requires that
the compensation arrangements of
persons performing the banking entity’s
market making-related activities, as
described in the exemption, are
designed not to reward or incentivize
prohibited proprietary trading.1025 The
language of the final compensation
requirement has been modified in
response to comments expressing
concern about the proposed language
regarding ‘‘proprietary risk-taking.’’ 1026
The Agencies note that the Agencies do
not intend to preclude an employee of
a market-making desk from being
compensated for successful market
making, which involves some risktaking.
The Agencies continue to hold the
view that activities for which a banking
entity has established a compensation
incentive structure that rewards
speculation in, and appreciation of, the
market value of a position held in
inventory, rather than use of that
inventory to successfully provide
effective and timely intermediation and
liquidity services to customers, are
inconsistent with permitted market
making-related activities. Although a
banking entity relying on the marketmaking exemption may appropriately
take into account revenues resulting
from movements in the price of
principal positions to the extent that
such revenues reflect the effectiveness
with which personnel have managed
retained principal risk, a banking entity
relying on the market-making
exemption should provide
compensation incentives that primarily
reward customer revenues and effective
customer service, not prohibited
proprietary trading.1027 For example, a
1024 See
Chamber (Dec. 2011).
final rule § ll.4(b)(2)(v).
1026 See Morgan Stanley; SIFMA et al. (Prop.
Trading) (Feb. 2012).
1027 Because the Agencies are not limiting a
market maker’s compensation to specific sources,
such as fees, commissions, and bid-ask spreads, as
recommended by a few commenters, the Agencies
do not believe the compensation requirement in the
final rule will incentivize market makers to widen
their quoted spreads or charge higher fees and
commissions, as suggested by certain other
commenters. See Better Markets (Feb. 2012); Public
Citizen; AllianceBernstein; Investure. In addition,
the Agencies note that an approach requiring
revenue from fees, commissions, and bid-ask
spreads to be fully distinguished from revenue from
price appreciation can raise certain practical
difficulties, as discussed in Part IV.A.3.c.7. The
Agencies also are not requiring compensation to be
vested for a period of time, as recommended by
some commenters to reduce traders’ incentives for
undue risk-taking. The Agencies believe the final
1025 See
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5619
compensation plan based purely on net
profit and loss with no consideration for
inventory control or risk undertaken to
achieve those profits would not be
consistent with the market-making
exemption.
6. Registration Requirement
a. Proposed Registration Requirement
Under § ll.4(b)(2)(iv) of the
proposed rule, a banking entity relying
on the market-making exemption with
respect to trading in securities or certain
derivatives would be required to be
appropriately registered as a securities
dealer, swap dealer, or security-based
swap dealer, or exempt from registration
or excluded from regulation as such
type of dealer, under applicable
securities or commodities laws. Further,
if the banking entity was engaged in the
business of a securities dealer, swap
dealer, or security-based swap dealer
outside the United States in a manner
for which no U.S. registration is
required, the banking entity would be
required to be subject to substantive
regulation of its dealing business in the
jurisdiction in which the business is
located.1028
b. Comments on the Proposed
Registration Requirement
A few commenters stated that the
proposed dealer registration
requirement is effective.1029 However, a
number of commenters opposed the
proposed dealer registration
requirement in whole or in part.1030
Commenters’ primary concern with the
requirement appeared to be its
application to market making-related
activities outside of the United States
for which no U.S. registration is
required.1031 For example, several
commenters stated that many non-U.S.
markets do not provide substantive
regulation of dealers for all asset
classes.1032 In addition, two
rule includes sufficient controls around risk-taking
activity without a compensation vesting
requirement. See John Reed; AFR et al. (Feb. 2012);
Johnson & Prof. Stiglitz; Prof. Duffie; Sens. Merkley
& Levin (Feb. 2012).
1028 See proposed rule § ll.4(b)(2)(iv); Joint
Proposal, 76 FR 68,872; CFTC Proposal, 77 FR
8357–8358.
1029 See Occupy; Alfred Brock.
1030 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(stating that if the requirement is not removed from
the rule, then it should only be an indicative factor
of market making); Morgan Stanley; Goldman (Prop.
Trading); ISDA (Feb. 2012).
1031 See Goldman (Prop. Trading); Morgan
Stanley; RBC; SIFMA et al. (Prop. Trading) (Feb.
2012); ISDA (Feb. 2012); JPMC. This issue is
addressed in note 1044 and its accompanying text,
infra.
1032 See Goldman (Prop. Trading); RBC; SIFMA et
al. (Prop. Trading) (Feb. 2012).
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commenters stated that booking entities
may be able to rely on intra-group
exemptions under local law rather than
carrying dealer registrations, or a
banking entity may execute customer
trades through an international dealer
but book the position in a non-dealer
entity for capital adequacy and risk
management purposes.1033 Several of
these commenters requested, at a
minimum, that the dealer registration
requirement not apply to dealers in nonU.S. jurisdictions.1034
In addition, with respect to the
provisions that would generally require
a banking entity to be a form of SEC- or
CFTC-registered dealer for marketmaking activities in securities or
derivatives in the United States, a few
commenters stated that these provisions
should be removed from the rule.1035
These commenters represented that
removing these provisions would be
appropriate for several reasons. For
example, one commenter stated that
dealer registration does not help
distinguish between market making and
speculative trading.1036 Another
commenter indicated that effective
market making often requires a banking
entity to trade on several exchange and
platforms in a variety of markets,
including through legal entities other
than SEC- or CFTC-registered dealer
entities.1037 One commenter expressed
general concern that the proposed
requirement may result in the marketmaking exemption being unavailable for
market making in exchange-traded
futures and options because those
markets do not have a corollary to
dealer registration requirements in
securities, swaps, and security-based
swaps markets.1038
Some commenters expressed
particular concern about the provisions
that would generally require registration
as a swap dealer or a security-based
swap dealer.1039 For example, one
commenter expressed concern that these
provisions may require banking
JPMC; Goldman (Prop. Trading).
Goldman (Prop. Trading); RBC; SIFMA et
al. (Prop. Trading) (Feb. 2012). See also Morgan
Stanley (requesting the addition of the phrase ‘‘to
the extent it is legally required to be subject to such
regulation’’ to the non-U.S. dealer provisions).
1035 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Morgan Stanley; ISDA
(Feb. 2012). Rather than remove the requirement
entirely, one commenter recommended that the
Agencies move the dealer registration requirement
to proposed Appendix B, which would allow the
Agencies to take into account the facts and
circumstances of a particular trading activity. See
JPMC.
1036 See SIFMA et al. (Prop. Trading) (Feb. 2012).
1037 See Goldman (Prop. Trading).
1038 See CME Group.
1039 See ISDA (Feb. 2012); SIFMA et al. (Prop.
Trading) (Feb. 2012).
regulators to redundantly enforce CFTC
and SEC registration requirements.
Moreover, according to this commenter,
the proposed definitions of ‘‘swap
dealer’’ and ‘‘security-based swap
dealer’’ do not focus on the market
making core of the swap dealing
business.1040 Another commenter stated
that incorporating the proposed
definitions of ‘‘swap dealer’’ and
‘‘security-based swap dealer’’ is contrary
to the Administrative Procedure Act.1041
c. Final Registration Requirement
The final requirement of the marketmaking exemption provides that the
banking entity must be licensed or
registered to engage in market makingrelated activity in accordance with
applicable law.1042 The Agencies have
considered comments regarding the
dealer registration requirement in the
proposed rule.1043 In response to
comments, the Agencies have narrowed
the scope of the proposed requirement’s
application to banking entities engaged
in market making-related activity in
foreign jurisdictions.1044 Rather than
requiring these banking entities to be
subject to substantive regulation of their
dealing business in the relevant foreign
jurisdiction, the final rule only require
a banking entity to be a registered dealer
in a foreign jurisdiction to the extent
required by applicable foreign law. The
Agencies have also simplified the
language of the proposed requirement,
although the Agencies have not
modified the scope of the requirement
with respect to U.S. dealer registration
requirements.
This provision is not intended to
expand the scope of licensing or
registration requirements under relevant
U.S. or foreign law that are applicable
to a banking entity engaged in marketmaking activities. Instead, this provision
recognizes that compliance with
applicable law is an essential indicator
that a banking entity is engaged in
1033 See
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1034 See
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1040 See
ISDA (Feb. 2012).
SIFMA et al. (Prop. Trading) (Feb. 2012).
1042 See final rule § ll.4(b)(2)(vi).
1043 See supra Part IV.A.3.c.5.b. One commenter
expressed concern that the instruments listed in
§ ll.4(b)(2)(iv) of the proposed rule could be
interpreted as limiting the availability of the
market-making exemption to other instruments,
such as exchange-traded futures and options. In
response to this comment, the Agencies note that
the reference to particular instruments in § ll
.4(b)(2)(iv) was intended to reflect that trading in
certain types of instruments gives rise to dealer
registration requirements. This provision was not
intended to limit the availability of the marketmaking exemption to certain types of financial
instruments. See CME Group.
1044 See Goldman (Prop. Trading); RBC; SIFMA et
al. (Prop. Trading) (Feb. 2012); Morgan Stanley.
1041 See
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market-making activities.1045 For
example, a U.S. banking entity would be
expected to be an SEC-registered dealer
to rely on the market-making exemption
for trading in securities—other than
exempted securities, security-based
swaps, commercial paper, bankers
acceptances, or commercial bills—
unless the banking entity is exempt
from registration or excluded from
regulation as a dealer.1046 Similarly, a
U.S. banking entity is expected to be a
CFTC-registered swap dealer or SECregistered security-based swap dealer to
rely on the market-making exemption
for trading in swaps or security-based
swaps, respectively,1047 unless the
banking entity is exempt from
registration or excluded from regulation
as a swap dealer or security-based swap
dealer.1048 In response to comments on
whether this provision should generally
require registration as a swap dealer or
security-based swap dealer to make a
market in swaps or security-based
swaps,1049 the Agencies continue to
1045 In response to commenters who stated that
the dealer registration requirement should be
removed from the rule because, among other things,
registration as a dealer does not distinguish
between permitted market making and
impermissible proprietary trading, the Agencies
recognize that acting as a registered dealer does not
ensure that a banking entity is engaged in permitted
market making-related activity. See SIFMA et al.
(Prop. Trading) (Feb. 2012); Goldman (Prop.
Trading); Morgan Stanley; ISDA (Feb. 2012).
However, this requirement recognizes that
registration as a dealer is an indicator of market
making-related activities in the circumstances in
which a person is legally obligated to be a registered
dealer to act as a market maker.
1046 A banking entity relying on the marketmaking exemption for transactions in securitybased swaps would generally be required to be a
registered security-based swap dealer and would
not be required to be a registered securities dealer.
However, a banking entity may be required to be
a registered securities dealer if it engages in marketmaking transactions involving security-based swaps
with persons that are not eligible contract
participants. The definition of ‘‘dealer’’ in section
3(a)(5) of the Exchange Act generally includes ‘‘any
person engaged in the business of buying and
selling securities (not including security-based
swaps, other than security-based swaps with or for
persons that are not eligible contract participants),
for such person’s own account.’’ 15 U.S.C. 78c(a)(5).
To the extent, if any, that a banking entity relies
on the market-making exemption for its trading in
municipal securities or government securities,
rather than the exemption in § ll.6(a) of the final
rule, this provision may require the banking entity
to be registered or licensed as a municipal securities
dealer or government securities dealer.
1047 As noted above, under certain circumstances,
a banking entity acting as market maker in securitybased swaps may be required to be a registered
securities dealer. See supra note 1046.
1048 For example, a banking entity meeting the
conditions of the de minimis exception in SEC Rule
3a71–2 under the Exchange Act would not need to
be a registered security-based swap dealer to act as
a market maker in security-based swaps. See 17
CFR 240.3a71–2.
1049 See ISDA (Feb. 2012); SIFMA et al. (Prop.
Trading) (Feb. 2012).
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believe that this requirement is
appropriate. In general, a person that is
engaged in making a market in swaps or
security-based swaps or other activity
causing oneself to be commonly known
in the trade as a market maker in swaps
or security-based swaps is required to be
a registered swap dealer or registered
security-based swap dealer, unless
exempt from registration or excluded
from regulation as such.1050 As noted
above, compliance with applicable law
is an essential indicator that a banking
entity is engaged in market-making
activities.
As noted above, the Agencies have
determined that, rather than require a
banking entity engaged in the business
of a securities dealer, swap dealer, or
security-based swap dealer outside the
United States to be subject to
substantive regulation of its dealing
business in the foreign jurisdiction in
which the business is located, a banking
entity’s dealing activity outside the U.S.
should only be subject to licensing or
registration requirements under
applicable foreign law (provided no U.S.
registration or licensing requirements
apply to the banking entity’s activities).
As a result, this requirement will not
impact a banking entity’s ability to
engage in permitted market makingrelated activities in a foreign
jurisdiction that does not provide for
substantive regulation of dealers.1051
7. Source of Revenue Analysis
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a. Proposed Source of Revenue
Requirement
To qualify for the market-making
exemption, the proposed rule required
that the market making-related activities
of the trading desk or other
organizational unit be designed to
generate revenues primarily from fees,
commissions, bid/ask spreads or other
income not attributable to appreciation
in the value of financial instrument
positions it holds in trading accounts or
the hedging of such positions.1052 This
proposed requirement was intended to
ensure that activities conducted in
reliance on the market-making
exemption demonstrate patterns of
revenue generation and profitability
consistent with, and related to, the
intermediation and liquidity services a
market maker provides to its customers,
rather than changes in the market value
1050 See 7 U.S.C. 1a(49)(A); 15 U.S.C.
78c(a)(71)(A).
1051 See Goldman (Prop. Trading); RBC; SIFMA et
al. (Prop. Trading) (Feb. 2012); Morgan Stanley.
This is consistent with one commenter’s suggestion
that the Agencies add ‘‘to the extent it is legally
required to be subject to such regulation’’ to the
non-U.S. dealer provisions. See Morgan Stanley.
1052 See proposed rule § ll.4(b)(2)(v).
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of the positions or risks held in
inventory.1053
b. Comments Regarding the Proposed
Source of Revenue Requirement
As discussed in more detail below,
many commenters expressed concern
about the proposed source of revenue
requirement. These commenters raised a
number of concerns including, among
others, the proposed requirement’s
potential impact on a market maker’s
inventory or on costs to customers, the
difficulty of differentiating revenues
from spreads and revenues from price
appreciation in certain markets, and the
need for market makers to be
compensated for providing
intermediation services.1054 Several of
these commenters requested that the
proposed source of revenue requirement
be removed from the rule or modified in
certain ways. Some commenters,
however, expressed support for the
proposed requirement or requested that
the Agencies place greater restrictions
on a banking entity’s permissible
sources of revenue under the marketmaking exemption.1055
i. Potential Restrictions on Inventory,
Increased Costs for Customers, and
Other Changes to Market-Making
Services
Many commenters stated that the
proposed source of revenue requirement
may limit a market maker’s ability to
hold sufficient inventory to facilitate
customer demand.1056 Several of these
commenters expressed particular
concern about applying this
requirement to less liquid markets or to
facilitating large customer positions,
where a market maker is more likely to
hold inventory for a longer period of
time and has increased risk of potential
price appreciation (or depreciation).1057
1053 See
Joint Proposal, 76 FR 68,872; CFTC
Proposal, 77 FR 8358.
1054 These concerns are addressed in Part
IV.A.3.c.7.c., infra.
1055 See infra note 1103 (responding to these
comments).
1056 See, e.g., NYSE Euronext; SIFMA et al. (Prop.
Trading) (Feb. 2012); Morgan Stanley; Goldman
(Prop. Trading); BoA; Citigroup (Feb. 2012);
STANY; BlackRock; SIFMA (Asset Mgmt.) (Feb.
2012); ACLI (Feb. 2012); T. Rowe Price; PUC Texas;
SSgA (Feb. 2012); ICI (Feb. 2012) Invesco; MetLife;
MFA.
1057 See, e.g., Morgan Stanley; BoA; BlackRock; T.
Rowe Price; Goldman (Prop. Trading); NYSE
Euronext (suggesting that principal trading by
market makers in large sizes is essential in some
securities, such as an AP’s trading in ETFs); Prof.
Duffie; SSgA (Feb. 2012); CIEBA; SIFMA et al.
(Prop. Trading) (Feb. 2012); MFA. To explain its
concern, one commenter stated that bid-ask spreads
are useful to capture the concept of market-making
revenues when a market maker is intermediating on
a close to real-time basis between balanced
customer buying and selling interest for the same
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5621
Further, another commenter questioned
how the proposed requirement would
apply when unforeseen market pressure
or disappearance of customer demand
results in a market maker holding a
particular position in inventory for
longer than expected.1058 In response to
this proposed requirement, a few
commenters stated that it is important
for market makers to be able to hold a
certain amount of inventory to: Provide
liquidity (particularly in the face of
order imbalances and market
volatility),1059 facilitate large trades, and
hedge positions acquired in the course
of market making.1060
Several commenters expressed
concern that the proposed source of
revenue requirement may incentivize a
market maker to widen its quoted
spreads or otherwise impose higher fees
to the detriment of its customers.1061
For example, some commenters stated
that the proposed requirement could
result in a market maker having to sell
a position in its inventory within an
artificially prescribed period of time
and, as a result, the market maker would
pay less to initially acquire the position
from a customer.1062 Other commenters
represented that the proposed source of
revenue requirement would compel
market makers to hedge their exposure
to price movements, which would likely
increase the cost of intermediation.1063
Some commenters stated that the
proposed source of revenue requirement
may make a banking entity less willing
to make markets in instruments that it
may not be able to resell immediately or
in the short term.1064 One commenter
indicated that this concern may be
heightened in times of market stress.1065
Further, a few commenters expressed
the view that the proposed requirement
would cause banking entities to exit the
instrument, but such close-in-time intermediation
does not occur in many large or illiquid assets,
where demand gaps may be present for days, weeks,
or months. See Morgan Stanley.
1058 See Capital Group.
1059 See NYSE Euronext; CIEBA (stating that if the
rule discourages market makers from holding
inventory, there will be reduced liquidity for
investors and issuers).
1060 See NYSE Euronext. For a more in-depth
discussion of comments regarding the benefits of
permitting market makers to hold and manage
inventory, See Part IV.A.3.c.2.b.vi., infra.
1061 See, e.g., Wellington; CIEBA; MetLife; ACLI
(Feb. 2012); SSgA (Feb. 2012); PUC Texas; ICI (Feb.
2012) BoA.
1062 See MetLife; ACLI (Feb. 2012); ICI (Feb. 2012)
SSgA (Feb. 2012).
1063 See SSgA (Feb. 2012); PUC Texas.
1064 See ICI (Feb. 2012) SSgA (Feb. 2012); SIFMA
(Asset Mgmt.) (Feb. 2012); BoA.
1065 See CIEBA (arguing that banking entities may
be reluctant to provide liquidity when markets are
declining and there are more sellers than buyers
because it would be necessary to hold positions in
inventory to avoid losses).
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market-making business due to
restrictions on their ability to make a
profit from market-making activities.1066
Moreover, in one commenter’s opinion,
the proposed requirement would
effectively compel market makers to
trade on an agency basis.1067
ii. Certain Price Appreciation-Related
Profits Are an Inevitable or Important
Component of Market Making
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A number of commenters indicated
that market makers will inevitably make
some profit from price appreciation of
certain inventory positions because
changes in market values cannot be
precisely predicted or hedged.1068 In
particular, several commenters
emphasized that matched or perfect
hedges are generally unavailable for
most types of positions.1069 According
to one commenter, a provision that
effectively requires a market-making
business to hedge all of its principal
positions would discourage essential
market-making activity. The commenter
explained that effective hedges may be
unavailable in less liquid markets and
hedging can be costly, especially in
relation to the relative risk of a trade
and hedge effectiveness.1070 A few
commenters further indicated that
making some profit from price
appreciation is a natural part of market
1066 See Credit Suisse (Seidel) (arguing that
banking entities are likely to cease being market
makers if they are: (i) Unable to take into account
the likely direction of a financial instrument, or (ii)
forced to take losses if a financial instrument moves
against them, but cannot take gains if the
instrument’s price moves in their favor); STANY
(contending that banking entities cannot afford to
maintain unprofitable or marginally profitable
operations in highly competitive markets, so this
requirement would cause banking entities to
eliminate a majority of their market-making
functions).
1067 See IR&M (arguing that domestic corporate
and securitized credit markets are too large and
heterogeneous to be served appropriately by a
primarily agency-based trading model).
1068 See Wellington; Credit Suisse (Seidel);
Morgan Stanley; PUC Texas (contending that it is
impossible to predict the behavior of even the most
highly correlated hedge in comparison to the
underlying position); CIEBA; SSgA (Feb. 2012);
AllianceBernstein; Investure; Invesco.
1069 See Morgan Stanley; Credit Suisse (Seidel);
SSgA (Feb. 2012); PUC Texas; Wellington;
AllianceBernstein; Investure.
1070 See Wellington. Moreover, one commenter
stated that, as a general matter, market makers need
to be compensated for bearing risk related to
providing immediacy to a customer. This
commenter stated that ‘‘[t]he greater the inventory
risk faced by the market maker, the higher the
expected return (compensation) that the market
maker needs,’’ to compensate the market maker for
bearing the risk and reward its specialization skills
in that market (e.g., its knowledge about market
conditions and early indicators that may imply
future price movements in a particular direction).
This commenter did not, however, discuss the
source of revenue requirement in the proposed rule.
See Thakor Study.
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making or is necessary to compensate a
market maker for its willingness to take
a position, and its associated risk (e.g.,
the risk of market changes or decreased
value), from a customer.1071
iii. Concerns Regarding the Workability
of the Proposed Standard in Certain
Markets or Asset Classes
Some commenters represented that it
would be difficult or burdensome to
identify revenue attributable to the bidask spread versus revenue arising from
price appreciation, either as a general
matter or for specific markets.1072 For
example, one commenter expressed the
opinion that the difference between the
bid-ask spread and price appreciation is
‘‘metaphysical’’ in some sense,1073
while another stated that it is almost
impossible to objectively identify a bidask spread or to capture profit and loss
solely from a bid-ask spread in most
markets.1074 Other commenters
represented that it is particularly
difficult to make this distinction when
trades occur infrequently or where
prices are not transparent, such as in the
fixed-income market where no spread is
published.1075
Many commenters expressed
particular concern about the proposed
requirement’s application to specific
markets, including: The fixed-income
markets; 1076 the markets for
commodities, derivatives, securitized
products, and emerging market
1071 See Capital Group; Prof. Duffie; Investure;
SIFMA et al. (Prop. Trading) (Feb. 2012); STANY;
SIFMA (Asset Mgmt.) (Feb. 2012); RBC; PNC.
1072 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Goldman (Prop. Trading); BoA; Citigroup
(Feb. 2012); Japanese Bankers Ass’n.; Sumitomo
Trust; Morgan Stanley; Barclays; RBC; Capital
Group.
1073 See SIFMA et al. (Prop. Trading) (Feb. 2012).
1074 See Citigroup (Feb. 2012). See also Barclays
(arguing that a bid-ask spread cannot be defined on
a consistent basis with respect to many
instruments).
1075 See Goldman (Prop. Trading); BoA; Morgan
Stanley (‘‘Observable, actionable, bid/ask spreads
exist in only a small subset of institutional products
and markets. Indicative bid/ask spreads may be
observable for certain products, but this pricing
would typically be specific to small size standard
lot trades and would not represent a spread
applicable to larger and/or more illiquid trades.
End-of-day valuations for assets are calculated, but
they are not an effective proxy for real-time bid/ask
spreads because of intra-day price movements.’’);
RBC; Capital Group (arguing that bid-ask spreads in
fixed-income markets are not always quantifiable or
well defined and can fluctuate widely within a
trading day because of small or odd lot trades, price
discovery activity, a lack of availability to cover
shorts, or external factors not directly related to the
security being traded).
1076 See Capital Group; CIEBA; SIFMA et al.
(Prop. Trading) (Feb. 2012); SSgA (Feb. 2012).
These commenters stated that the requirement may
be problematic for the fixed-income markets
because, for example, market makers must hold
inventory in these markets for a longer period of
time than in more liquid markets. See id.
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securities; 1077 equity and physical
commodity derivatives markets; 1078 and
customized swaps used by customers of
banking entities for hedging
purposes.1079 Another commenter
expressed general concern about
extremely volatile markets, where
market makers often see large upward or
downward price swings over time.1080
Two commenters emphasized that the
revenues a market maker generates from
hedging the positions it holds in
inventory are equivalent to spreads in
many markets. These commenters
explained that, under these
circumstances, a market maker
generates revenue from the difference
between the customer price for the
position and the banking entity’s price
for the hedge. The commenters noted
that proposed Appendix B expressly
recognizes this in the case of derivatives
and recommended that Appendix B’s
guidance on this point apply equally to
certain non-derivative positions.1081
A few commenters questioned how
this requirement would work in the
context of block trading or otherwise
facilitating large trades, where a market
maker may charge a premium or
discount for taking on a large position
1077 See SIFMA et al. (Prop. Trading) (Feb. 2012)
(stating that these markets are characterized by even
less liquidity and less frequent trading than the U.S.
corporate bond market). This commenter also stated
that in markets where trades are large and less
frequent, such as the market for customized
securitized products, appreciation in price of one
position may be a predominate contributor to the
overall profit and loss of the trading unit. See id.
1078 See BoA. According to this commenter, the
distinction between capturing a spread and price
appreciation is fundamentally flawed in some
markets, like equity derivatives, because the market
does not trade based on movements of a particular
security or underlying instrument. This commenter
indicated that expected returns are instead based on
the bid-ask spread the market maker charges for
implied volatility as reflected in options premiums
and hedging of the positions. See id.
1079 See CIEBA (stating that because it would be
difficult for a market maker to enter promptly into
an offsetting swap, the market maker would not be
able to generate income from the spread).
1080 See SIFMA et al. (Prop. Trading) (Feb. 2012).
This commenter questioned whether proposed
Appendix B’s reference to ‘‘unexpected market
disruptions’’ as an explanatory fact and
circumstance was intended to permit such market
making. See id.
1081 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading). In its discussion of
‘‘customer revenues,’’ Appendix B states: ‘‘In the
case of a derivative contract, these revenues reflect
the difference between the cost of entering into the
derivative contract and the cost of hedging
incremental, residual risks arising from the
contract.’’ Joint Proposal, 76 FR 68,960; CFTC
Proposal, 77 FR 8440. See also RBC (requesting
clarification on how the proposed standard would
apply if a market maker took an offsetting position
in a different instrument (e.g., a different bond) and
inquiring whether, if the trader took the offsetting
position, its revenue gain is attributable to price
appreciation of the two offsetting positions or from
the bid-ask spread in the respective bonds).
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to provide ‘‘immediacy’’ to its
customer.1082 One commenter further
explained that explicitly quoted bid-ask
spreads are only valid for indicated
trade sizes that are modest enough to
have negligible market impact, and such
spreads cannot be used for purposes of
a significantly larger trade.1083
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iv. Suggested Modifications to the
Proposed Requirement
To address some or all of the concerns
discussed above, many commenters
recommended that the source of
revenue requirement be modified 1084 or
removed from the rule entirely.1085 With
respect to suggested changes, some
commenters stated that the Agencies
should modify the rule text,1086 use a
metrics-based approach to focus on
customer revenues,1087 or replace the
proposed requirement with
guidance.1088 Some commenters
requested that the Agencies modify the
focus of the requirement so that, for
example, dealers’ market-making
activities in illiquid securities can
function as close to normal as
possible 1089 or market makers can take
short-term positions that may ultimately
1082 See Prof. Duffie; NYSE Euronext; Capital
Group; RBC; Goldman (Prop. Trading). See also
Thakor Study (discussing market makers’ role of
providing ‘‘immediacy’’ in general).
1083 See CIEBA.
1084 See, e.g., JPMC; Barclays; Goldman (Prop.
Trading); BoA; CFA Inst.; ICI (Feb. 2012) Flynn &
Fusselman.
1085 See, e.g., CIEBA; SIFMA et al. (Prop. Trading)
(Feb. 2012); Morgan Stanley; Goldman (Prop.
Trading); Capital Group; RBC. In addition to the
concerns discussed above, one commenter stated
that the proposed requirement may set limits on the
values of certain metrics, and it would be
inappropriate to prejudge the appropriate results of
such metrics at this time. See SIFMA et al. (Prop.
Trading) (Feb. 2012).
1086 See, e.g., Barclays. This commenter provided
alternative rule text stating that ‘‘market makingrelated activity is conducted by each trading unit
such that its activities are reasonably designed to
generate revenues primarily from fees,
commissions, bid-ask spreads, or other income
attributable to satisfying reasonably expected
customer demand.’’ See id.
1087 See Goldman (Prop. Trading) (suggesting that
the Agencies use a metrics-based approach to focus
on customer revenues, as measured by Spread Profit
and Loss (when it is feasible to calculate) or other
metrics, especially because a proprietary trading
desk would not be expected to earn any revenues
this way). This commenter also indicated that the
‘‘primarily’’ standard in the proposed rule is
problematic and can be read to mean ‘‘more than
50%,’’ which is different from Appendix B’s
acknowledgment that the proportion of customer
revenues relative to total revenues will vary by asset
class. See id.
1088 See BoA (recommending that the guidance
state that the Agencies would consider the design
and mix of such revenues as an indicator of
potentially prohibited proprietary trading, but only
for those markets for which revenues are
quantifiable based on publicly available data, such
as segments of certain highly liquid equity markets).
1089 See CFA Inst.
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result in a profit or loss.1090 As
discussed below, some commenters
stated that the Agencies should modify
the proposed requirement to place
greater restrictions on market maker
revenue.
v. General Support for the Proposed
Requirement or for Placing Greater
Restrictions on a Market Maker’s
Sources of Revenue
Some commenters expressed support
for the proposed source of revenue
requirement or stated that the
requirement should be more
restrictive.1091 For example, one of these
commenters stated that a real market
maker’s trading book should be fully
hedged, so it should not generate profits
in excess of fees and commissions
except in times of rare and
extraordinary market conditions.1092
According to another commenter, the
final rule should make it clear that
banking entities seeking to rely on the
market-making exemption may not
generally seek to profit from price
movements in their inventories,
although their activities may give rise to
modest and relatively stable profits
arising from their limited inventory.1093
One commenter recommended that the
proposed requirement be interpreted to
limit market making in illiquid
positions because a banking entity
cannot have the required revenue
motivation when it enters into a
position for which there is no readily
discernible exit price.1094
Further, some commenters suggested
that the Agencies remove the word
‘‘primarily’’ from the provision to limit
banking entities to specified sources of
revenue.1095 In addition, one of these
commenters requested that the Agencies
restrict a market maker’s revenue to fees
and commissions and remove the
allowance for revenue from bid-ask
1090 See
ICI (Feb. 2012).
Sens. Merkley & Levin (Feb. 2012); Better
Markets (Feb. 2012); FTN; Public Citizen; Occupy;
Alfred Brock.
1092 See Better Markets (Feb. 2012). See also
Public Citizen (arguing that the imperfection of a
hedge should signal potential disqualification of the
underlying position from the market-making
exemption).
1093 See Sens. Merkley & Levin (Feb. 2012). This
commenter further suggested that the rule identify
certain red flags and metrics that could be used to
monitor this requirement, such as: (i) Failure to
obtain relatively low ratios of revenue-to-risk, low
volatility, and relatively high turnover; (ii)
significant revenues from price appreciation
relative to the value of securities being traded; (iii)
volatile revenues from price appreciation; or (iv)
revenue from price appreciation growing out of
proportion to the risk undertaken with the security.
See id.
1094 See AFR et al. (Feb. 2012).
1095 See Occupy; Better Markets (Feb. 2012). See
supra note 1103 (addressing these comments).
1091 See
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5623
spreads because generating bid-ask
revenues relies exclusively on changes
in market values of positions held in
inventory.1096 For enforcement
purposes, a few commenters suggested
that the Agencies require banking
entities to disgorge any profit obtained
from price appreciation.1097
c. Final Rule’s Approach to Assessing
Revenues
Unlike the proposed rule, the final
rule does not include a requirement that
a trading desk’s market making-related
activity be designed to generate revenue
primarily from fees, commissions, bidask spreads, or other income not
attributable to appreciation in the value
of a financial instrument or hedging.1098
The revenue requirement was one of the
most commented upon aspects of the
market-making exemption in the
proposal.1099
The Agencies believe that an analysis
of patterns of revenue generation and
profitability can help inform a judgment
regarding whether trading activity is
consistent with the intermediation and
liquidity services that a market maker
provides to its customers in the context
of the liquidity, maturity, and depth of
the relevant market, as opposed to
prohibited proprietary trading activities.
To facilitate this type of analysis, the
Agencies have included a metrics data
reporting requirement that is refined
from the proposed metric regarding
profits and losses. The Comprehensive
Profit and Loss Attribution metric
collects information regarding the daily
fluctuation in the value of a trading
desk’s positions to various sources,
along with its volatility, including: (i)
Profit and loss attributable to current
positions that were also held by the
banking entity as of the end of the prior
day (‘‘existing positions); (ii) profit and
loss attributable to new positions
resulting from the current day’s trading
activity (‘‘new positions’’); and (iii)
residual profit and loss that cannot be
specifically attributed to existing
positions or new positions.1100
This quantitative measurement has
certain conceptual similarities to the
proposed source of revenue requirement
in § ll.4(b)(2)(v) of the proposed rule
1096 See
Occupy.
Occupy; Public Citizen.
1098 See proposed rule § ll.4(b)(2)(v).
1099 See infra Part IV.A.3.c.7.b.
1100 See Appendix A of the final rule (describing
the Comprehensive Profit and Loss Attribution
metric). This approach is generally consistent with
one commenter’s suggested metrics-based approach
to focus on customer-related revenues. See
Goldman (Prop. Trading); See also Sens. Merkley &
Levin (Feb. 2012) (suggesting the use of metrics to
monitor a firm’s source of revenue); proposed
Appendix A.
1097 See
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sroberts on DSK5SPTVN1PROD with RULES
and certain of the proposed quantitative
measurements.1101 However, in
response to comments on those
provisions, the Agencies have
determined to modify the focus from
particular revenue sources (e.g., fees,
commissions, bid-ask spreads, and price
appreciation) to when the trading desk
generates revenue from its positions.
The Agencies recognize that when the
trading desk is engaged in market
making-related activities, the day one
profit and loss component of the
Comprehensive Profit and Loss
Attribution metric may reflect customergenerated revenues, like fees,
commissions, and spreads (including
embedded premiums or discounts), as
well as that day’s changes in market
value. Thereafter, profit and loss
associated with the position carried in
the trading desk’s book may reflect
changes in market price until the
position is sold or unwound. The
Agencies also recognize that the metric
contains a residual component for profit
and loss that cannot be specifically
attributed to existing positions or new
positions.
The Agencies believe that evaluation
of the Comprehensive Profit and Loss
Attribution metric could provide
valuable information regarding patterns
of revenue generation by market-making
trading desks involved in marketmaking activities that may warrant
further review of the desk’s activities,
while eliminating the requirement from
the proposal that the trading desk
demonstrate that its primary source of
revenue, under all circumstances, is
fees, commissions and bid/ask spreads.
This modified focus will reduce the
burden associated with the proposed
source of revenue requirement and
better account for the varying depth and
liquidity of markets.1102 In addition, the
1101 See supra Part IV.A.3.c.7. and infra Part
IV.C.3.
1102 The Agencies understand that some
commenters interpreted the proposed requirement
as requiring that both the bid-ask spread for a
financial instrument and the revenue a market
maker acquired from such bid-ask spread through
a customer trade be identifiable on a close-to-realtime basis and readily distinguishable from any
additional revenue gained from price appreciation
(both on the day of the transaction and for the rest
of the holding period). See, e.g., SIFMA et al. (Prop.
Trading) (Feb. 2012); Goldman (Prop. Trading);
BoA; Citigroup (Feb. 2012); Japanese Bankers
Ass’n.; Sumitomo Trust; Morgan Stanley; Barclays;
RBC; Capital Group. We recognize that such a
requirement would be unduly burdensome. In fact,
the proposal noted that bid-ask spreads or similar
spreads may not be widely disseminated on a
consistent basis or otherwise reasonably
ascertainable in certain asset classes for purposes of
the proposed Spread Profit and Loss metric in
Appendix A of the proposal. See Joint Proposal, 76
FR 68,958–68,959; CFTC Proposal, 77 FR 8438.
Moreover, the burden associated with the proposed
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Agencies believe these modifications
appropriately address commenters’
concerns about the proposed source of
revenue requirement and reduce the
potential for negative market impacts of
the proposed requirement cited by
commenters, such as incentives to
widen spreads or disincentives to
engage in market making in less liquid
markets.1103
The Agencies recognize that this
analysis is only informative over time,
and should not be determinative of an
analysis of whether the amount, types,
and risks of the financial instruments in
the trading desk’s market-maker
inventory are designed not to exceed the
reasonably expected near term demands
of clients, customers, or counterparties.
The Agencies believe this quantitative
measurement provides appropriate
flexibility to obtain information on
market-maker revenues, which is
designed to address commenters’
concerns about the proposal’s source of
revenue requirement (e.g., the burdens
requirement should be further reduced because we
are not adopting a stand-alone requirement
regarding a trading desk’s source of revenue.
Instead, when and how a trading desk generates
profit and loss from its trading activities is a factor
that must be considered for purposes of the near
term customer demand requirement. It is not a
dispositive factor for determining compliance with
the exemption.
Further, some commenters expressed concern
that the proposed requirement suggested market
makers were not permitted to profit from price
appreciation, but rather only from observable
spreads or explicit fees or commissions. See, e.g.,
Wellington, Credit Suisse (Seidel); Morgan Stanley;
PUC Texas; CIEBA; SSgA (Feb. 2012);
AllianceBernstein; Investure; Invesco. The Agencies
confirm that the intent of the market-making
exemption is not to preclude a trading desk from
generating any revenue from price appreciation.
Because this approach clarifies that a trading desk’s
source of revenue is not limited to its quoted
spread, the Agencies believe this quantitative
measurement will address commenters concerns
that the proposed source of revenue requirement
could create incentives for market makers to widen
their spreads, result in higher transaction costs,
require market makers to hedge any exposure to
price movements, or discourage a trading desk from
making a market in instruments that it may not be
able to sell immediately. See Wellington; CIEBA;
MetLife; ACLI (Feb. 2012); SSgA (Feb. 2012); PUC
Texas; ICI (Feb. 2012) BoA; SIFMA (Asset Mgmt.)
(Feb. 2012). The modifications to this provision are
designed to better reflect when, on average and
across many transactions, profits are gained rather
than how they are gained, similar to the way some
firms measure their profit and loss today. See, e.g.,
Goldman (Prop. Trading).
1103 See, e.g., Wellington; CIEBA; MetLife; ACLI
(Feb. 2012); SSgA (Feb. 2012); PUC Texas; ICI (Feb.
2012) BoA. The Agencies are not adopting an
approach that limits a market maker to specified
revenue sources (e.g., fees, commissions, and
spreads), as suggested by some commenters, due to
the considerations discussed above. See Occupy;
Better Markets (Feb. 2012). In response to the
proposed source of revenue requirement, some
commenters noted that a market maker may charge
a premium or discount for taking on a large position
from a customer. See Prof. Duffie; NYSE Euronext;
Capital Group; RBC; Goldman (Prop. Trading).
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associated with differentiating spread
revenue from price appreciation
revenue) while also helping assess
patterns of revenue generation that may
be informative over time about whether
a market maker’s activities are designed
to facilitate and provide customer
intermediation.
8. Appendix B of the Proposed Rule
a. Proposed Appendix B Requirement
The proposed market-making
exemption would have required that the
market making-related activities of the
trading desk or other organizational unit
of the banking entity be consistent with
the commentary in proposed Appendix
B.1104 In this proposed Appendix, the
Agencies provided overviews of
permitted market making-related
activity and prohibited proprietary
trading activity.1105
The proposed Appendix also set forth
various factors that the Agencies
proposed to use to help distinguish
prohibited proprietary trading from
permitted market making-related
activity. More specifically, proposed
Appendix B set forth six factors that,
absent explanatory facts and
circumstances, would cause particular
trading activity to be considered
prohibited proprietary trading activity
and not permitted market makingrelated activity. The proposed factors
focused on: (i) Retaining risk in excess
of the size and type required to provide
intermediation services to customers
(‘‘risk management factor’’); (ii)
primarily generating revenues from
price movements of retained principal
positions and risks, rather than
customer revenues (‘‘source of revenues
factor’’); (iii) generating only very small
or very large amounts of revenue per
unit of risk, not demonstrating
consistent profitability, or
demonstrating high earnings volatility
(‘‘revenues relative to risk factor’’); (iv)
not trading through a trading system
that interacts with orders of others or
primarily with customers of the banking
entity’s market-making desk to provide
liquidity services, or retaining principal
positions in excess of reasonably
expected near term customer demands
(‘‘customer-facing activity factor’’); (v)
routinely paying rather than earning
fees, commissions, or spreads
(‘‘payment of fees, commissions, and
spreads factor’’); and (vi) providing
compensation incentives to employees
that primarily reward proprietary riskproposed rule § ll.4(b)(2)(vi).
Joint Proposal, 76 FR 68,873, 68,960–
68,961; CFTC Proposal, 77 FR 8358, 8439–8440.
1104 See
1105 See
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taking (‘‘compensation incentives
factor’’).1106
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b. Comments on Proposed Appendix B
Commenters expressed differing
views about the accuracy of the
commentary in proposed Appendix B
and the appropriateness of including
such commentary in the rule. For
example, some commenters stated that
the description of market makingrelated activity in the proposed
appendix is accurate 1107 or
appropriately accounts for differences
among asset classes.1108 Other
commenters indicated that the appendix
is too strict or narrow.1109 Some
commenters recommended that the
Agencies revise proposed Appendix B’s
approach by, for example, placing
greater focus on what market making is
rather than what it is not,1110 providing
presumptions of activity that will be
treated as permitted market makingrelated activity,1111 re-formulating the
appendix as nonbinding guidance,1112
or moving certain requirements of the
proposed exemption to the
appendix.1113 One commenter suggested
1106 See Joint Proposal, 76 FR 68,873, 68,961–
68,963; CFTC Proposal, 77 FR 8358, 8440–8442.
1107 See MetLife; ACLI (Feb. 2012).
1108 See Alfred Brock. But See, e.g., Occupy
(stating that the proposed commentary only
accounts for the most liquid and transparent
markets and fails to accurately describe market
making in most illiquid or OTC markets).
1109 See Morgan Stanley; IIF; Sumitomo Trust;
ISDA (Apr. 2012); BDA (Feb. 2012) (Oct. 2012)
(stating that proposed Appendix B places too great
of a focus on derivatives trading and does not
reflect how principal trading operations in equity
and fixed income markets are structured). One of
these commenters requested that the appendix be
modified to account for certain activities conducted
in connection with market making in swaps. This
commenter indicated that a swap dealer may not
regularly enjoy a dominant flow of customer
revenues and may consistently need to make
revenue from its book management. In addition, the
commenter stated that the appendix should
recognize that making a two-way market may be a
dominant theme, but there are certain to be frequent
occasions when, as a matter of market or internal
circumstances, a market maker is unavailable to
trade. See ISDA (Apr. 2012).
1110 See SIFMA et al. (Prop. Trading) (Feb. 2012).
1111 See Sens. Merkley & Levin (Feb. 2012). This
commenter stated that, for example, Appendix B
could deem market making involving widely-traded
stocks and bonds issued by well-established
corporations, government securities, or highly
liquid asset-backed securities as the type of plain
vanilla, low risk capital activities that are
presumptively permitted, provided the activity is
within certain, specified parameters for inventory
levels, revenue-to-risk metrics, volatility, and
hedging. See id.
1112 See Morgan Stanley; Flynn & Fusselman.
1113 See JPMC. In support of such an approach,
the commenter argued that sometimes proposed
§ ll.4(b) and Appendix B addressed the same
topic and, when this occurs, it is unclear whether
compliance with Appendix B constitutes
compliance with § ll.4(b) or if additional
compliance steps are required. See id.
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the Agencies remove Appendix B from
the rule and instead use the
conformance period to analyze and
develop a body of supervisory guidance
that appropriately characterizes the
nature of market making-related
activity.1114
A few commenters expressed concern
about the appendix’s facts-andcircumstances-based approach to
distinguishing between prohibited
proprietary trading and permitted
market making-related activity and
stated that such an approach will make
it more difficult or burdensome for
banking entities to comply with the
proposed rule 1115 or will generate
regulatory uncertainty.1116 As discussed
below, other commenters opposed
proposed Appendix B because of its
level of granularity 1117 or due to
perceived restrictions on interdealer
trading or generating revenue from
retained principal positions or risks in
the proposed appendix.1118 A number of
commenters expressed concern about
the complexity or prescriptiveness of
the six proposed factors for
distinguishing permitted market
making-related activity from prohibited
proprietary trading.1119
With respect to the level of
granularity of proposed Appendix B, a
number of commenters expressed
concern that the reference to a ‘‘single
significant transaction’’ indicated that
the Agencies will review compliance
with the proposed market-making
exemption on a trade-by-trade basis and
stated that assessing compliance at the
level of individual transactions would
be unworkable.1120 One of these
commenters further stated that assessing
compliance at this level of granularity
would reduce a market maker’s
willingness to execute a customer sell
1114 See
Morgan Stanley.
NYSE Euronext; Morgan Stanley.
1116 See IAA.
1117 See Wellington; Goldman (Prop. Trading);
SIFMA (Asset Mgmt.) (Feb. 2012).
1118 See Morgan Stanley; Chamber (Feb. 2012);
Goldman (Prop. Trading).
1119 See Japanese Bankers Ass’n.; Credit Suisse
(Seidel); Chamber (Feb. 2012); ICFR; Morgan
Stanley; Goldman (Prop. Trading); Occupy; Oliver
Wyman (Feb. 2012); Oliver Wyman (Dec. 2011);
Public Citizen; NYSE Euronext. But See Alfred
Brock (stating that the proposed factors are
effective).
1120 See Wellington; Goldman (Prop. Trading);
SIFMA (Asset Mgmt.) (Feb. 2012). In particular,
proposed Appendix B provided that ‘‘The particular
types of trading activity described in this appendix
may involve the aggregate trading activities of a
single trading unit, a significant number or series
of transactions occurring at one or more trading
units, or a single significant transaction, among
other potential scenarios.’’ Joint Proposal, 76 FR
68,961; CFTC Proposal, 77 FR 8441. The Agencies
address commenters’ trade-by-trade concerns in
Part IV.A.3.c.1.c.ii., infra.
1115 See
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5625
order as principal due to concern that
the market maker may not be able to
immediately resell such position. The
commenter noted that this chilling
effect would be heightened in declining
markets.1121
A few commenters interpreted certain
statements in proposed Appendix B as
limiting interdealer trading and
expressed concerns regarding potential
limitations on this activity.1122 These
commenters emphasized that market
makers may need to trade with noncustomers to: (i) Provide liquidity to
other dealers and, indirectly, their
customers, or to otherwise allow
customers to access a larger pool of
liquidity; 1123 (ii) conduct price
discovery to inform the prices a market
maker can offer to customers; 1124 (iii)
unwind or sell positions acquired from
customers; 1125 (iv) establish or acquire
positions to meet reasonably expected
near term customer demand; 1126 (v)
hedge; 1127 and (vi) sell a financial
instrument when there are more buyers
than sellers for the instrument at that
time.1128 Further, one of these
commenters expressed the view that the
proposed appendix’s statements are
inconsistent with the statutory marketmaking exemption’s reference to
‘‘counterparties.’’ 1129
1121 See
Goldman (Prop. Trading).
Morgan Stanley; Goldman (Prop.
Trading); Chamber (Feb. 2012). Specifically,
commenters cited statements in proposed Appendix
B indicating that market makers ‘‘typically only
engage in transactions with non-customers to the
extent that these transactions directly facilitate or
support customer transactions.’’ On this issue, the
appendix further stated that ‘‘a market maker
generally only transacts with non-customers to the
extent necessary to hedge or otherwise manage the
risks of its market making-related activities,
including managing its risk with respect to
movements of the price of retained principal
positions and risks, to acquire positions in amounts
consistent with reasonably expected near term
demand of its customers, or to sell positions
acquired from its customers.’’ The appendix
recognized, however, that the ‘‘appropriate
proportion of a market maker’s transactions that are
with customers versus non-customers varies
depending on the type of positions involved and
the extent to which the positions are typically
hedged in non-customer transactions.’’ Joint
Proposal, 76 FR 68,961; CFTC Proposal, 77 FR 8440.
Commenters’ concerns regarding interdealer trading
are addressed in Part IV.A.3.c.2.c.i., infra.
1123 See Morgan Stanley; Goldman (Prop.
Trading).
1124 See Morgan Stanley; Goldman (Prop.
Trading); Chamber (Feb. 2012).
1125 See Morgan Stanley; Chamber (Feb. 2012)
(stating that market makers in the corporate bond,
interest rate derivative, and natural gas derivative
markets frequently trade with other dealers to work
down a concentrated position originating with a
customer trade).
1126 See Morgan Stanley; Chamber (Feb. 2012).
1127 See Goldman (Prop. Trading).
1128 See Chamber (Feb. 2012).
1129 See Goldman (Prop. Trading).
1122 See
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In addition, a few commenters
expressed concern about statements in
proposed Appendix B about a market
maker’s source of revenue.1130
According to one commenter, the
statement that profit and loss generated
by inventory appreciation or
depreciation must be ‘‘incidental’’ to
customer revenues is inconsistent with
market making-related activity in less
liquid assets and larger transactions
because market makers often must
retain principal positions for longer
periods of time in such circumstances
and are unable to perfectly hedge these
positions.1131 As discussed above with
respect to the source of revenue
requirement in § ll.4(b)(v) of the
proposed rule, a few commenters
requested that Appendix B’s discussion
of ‘‘customer revenues’’ be modified to
state that revenues from hedging will be
considered to be customer revenues in
certain contexts beyond derivatives
contracts.1132
A number of commenters discussed
the six proposed factors in Appendix B
that, absent explanatory facts and
circumstances, would have caused a
particular trading activity to be
considered prohibited proprietary
trading activity and not permitted
market making-related activity.1133 With
respect to the proposed factors, one
commenter indicated that they are
appropriate,1134 while another
commenter stated that they are complex
and their effectiveness is uncertain.1135
Another commenter expressed the view
that ‘‘[w]hile each of the selected factors
provides evidence of ‘proprietary
trading,’ warrants regulatory attention,
and justifies a shift in the burden of
proof, some require subjective
judgments, are subject to gaming or data
manipulation, and invite excessive
reliance on circumstantial evidence and
lawyers’ opinions.’’ 1136
1130 See Morgan Stanley; SIFMA et al. (Prop.
Trading) (Feb. 2012); Goldman (Prop. Trading). On
this issue, Appendix B stated that certain types of
‘‘customer revenues’’ provide the primary source of
a market maker’s profitability and, while a market
maker also incurs losses or generates profits as price
movements occur in its retained principal positions
and risks, ‘‘such losses or profits are incidental to
customer revenues and significantly limited by the
banking entity’s hedging activities.’’ Joint Proposal,
76 FR 68,960; CFTC Proposal, 77 FR 8440. The
Agencies address commenters’ concerns about
proposed requirements regarding a market maker’s
source of revenue in Part IV.A.3.c.7.c., infra.
1131 See Morgan Stanley.
1132 See supra note 1081 and accompanying text.
1133 See supra note 1106 and accompanying text.
1134 See Alfred Brock.
1135 See Japanese Bankers Ass’n.
1136 Sens. Merkley & Levin (Feb. 2012).
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In response to the proposed risk
management factor,1137 one commenter
expressed concern that it could prevent
a market maker from warehousing
positions in anticipation of predictable
but unrealized customer demands and,
further, could penalize a market maker
that misestimated expected demand.
This commenter expressed the view that
such an outcome would be contrary to
the statute and would harm market
liquidity.1138 Another commenter
requested that this presumption be
removed because in less liquid markets,
such as markets for corporate bonds,
equity derivatives, securitized products,
emerging markets, foreign exchange
forwards, and fund-linked products, a
market maker needs to act as principal
to facilitate client requests and, as a
result, will be exposed to risk.1139
Two commenters expressed concern
about the proposed source of revenue
factor.1140 One commenter stated that
this factor does not accurately reflect
how market making occurs in a majority
of markets and asset classes.1141 The
other commenter expressed concern that
this factor shifted the emphasis of § ll
.4(b)(v) of the proposed rule, which
required that market making-related
activities be ‘‘designed’’ to generate
revenue primarily from certain sources,
to the actual outcome of activities.1142
With respect to the proposed revenues
relative to risk factor, one commenter
supported this aspect of the
proposal.1143 Some commenters,
however, expressed concern about using
these factors to differentiate permitted
market making-related activity from
1137 The proposed appendix stated that the
Agencies would use certain quantitative
measurements required in proposed Appendix A to
help assess the extent to which a trading unit’s risks
are potentially being retained in excess amounts,
including VaR, Stress VaR, VaR Exceedance, and
Risk Factor Sensitivities. See Joint Proposal, 76 FR
68,961–68,962; CFTC Proposal, 77 FR 8441. One
commenter questioned whether, assuming such
metrics are effective and the activity does not
exceed the banking entity’s expressed risk appetite,
it is necessary to place greater restrictions on risktaking, based on the Agencies’ judgment of the level
of risk necessary for bona fide market making. See
ICFR.
1138 See Chamber (Feb. 2012).
1139 See Credit Suisse (Seidel).
1140 See Goldman (Prop. Trading); Morgan
Stanley.
1141 See Morgan Stanley.
1142 See Goldman (Prop. Trading). This
commenter suggested that the Agencies remove any
negative presumptions based on revenues and
instead use revenue metrics, such as Spread Profit
and Loss (when it is feasible to calculate) or other
metrics for purposes of monitoring a banking
entity’s trading activity. See id.
1143 See Occupy (stating that these factors are
important and will provide invaluable information
about the nature of the banking entity’s trading
activity).
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prohibited proprietary trading.1144
These commenters stated that volatile
risk-taking and revenue can be a natural
result of principal market-making
activity.1145 One commenter noted that
customer flows are often ‘‘lumpy’’ due
to, for example, a market maker’s
facilitation of large trades.1146
A few commenters indicated that the
analysis in the proposed customerfacing activity factor may not accurately
reflect how market making occurs in
certain markets and asset classes due to
potential limitations on interdealer
trading.1147 According to another
commenter, however, a banking entity’s
non-customer facing trades should be
required to be matched with existing
customer counterparties.1148 With
respect to the near term customer
demand component of this factor, one
commenter expressed concern that it
goes farther than the statute’s activitybased ‘‘design’’ test by analyzing
whether a trading unit’s inventory has
exceeded reasonably expected near term
customer demand at any particular
point in time.1149
Some commenters expressed concern
about the payment of fees, commissions,
and spreads factor.1150 One commenter
appeared to support this proposed
factor.1151 According to one commenter,
this factor fails to recognize that market
makers routinely pay a variety of fees in
connection with their market makingrelated activity, including, for example,
fees to access liquidity on another
market to satisfy customer demand,
transaction fees as a matter of course,
and fees in connection with hedging
transactions. This commenter also
indicated that, because spreads in
current, rapidly-moving markets are
volatile, short-term measurements of
profit compared to spread revenue is
problematic, particularly for less liquid
1144 See Morgan Stanley; Credit Suisse (Seidel);
Oliver Wyman (Feb. 2012); Oliver Wyman (Dec.
2011).
1145 See Morgan Stanley; Credit Suisse (Seidel);
Oliver Wyman (Feb. 2012); Oliver Wyman (Dec.
2011). For example, one commenter stated that
because markets and trading volumes are volatile,
consistent profitability and low earnings volatility
are outside a market maker’s control. In support of
this statement, the commenter indicated that: (i)
customer trading activity varies significantly with
market conditions, which results in volatility in a
market maker’s earnings and profitability; and (ii)
a market maker will experience volatility associated
with changes in the value of its inventory positions,
and principal risk is a necessary feature of market
making. See Morgan Stanley.
1146 See Oliver Wyman (Feb. 2012); Oliver
Wyman (Dec. 2011).
1147 See Morgan Stanley; Goldman (Prop.
Trading).
1148 See Public Citizen.
1149 See Oliver Wyman (Feb. 2012).
1150 See NYSE Euronext; Morgan Stanley.
1151 See Public Citizen.
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stocks.1152 Another commenter stated
that this factor reflects a bias toward
agency trading and principal market
making in highly liquid, exchangetraded markets and does not reflect the
nature of principal market making in
most markets.1153 One commenter
recommended that the rule require that
a trader who pays a fee be prepared to
document the chain of custody to show
that the instrument is shortly re-sold to
an interested customer.1154
Regarding the proposed compensation
incentives factor, one commenter
requested that the Agencies make clear
that explanatory facts and
circumstances cannot justify a trading
unit providing compensation incentives
that primarily reward proprietary risktaking to employees engaged in market
making. In addition, the commenter
recommended that the Agencies delete
the word ‘‘primarily’’ from this
factor.1155
c. Determination To Not Adopt
Proposed Appendix B
To improve clarity, the final rule
establishes particular criteria for the
exemption and does not incorporate the
commentary in proposed Appendix B
regarding the identification of permitted
market making-related activities. This
SUPPLEMENTARY INFORMATION provides
guidance on the standards for
compliance with the market-making
exemption.
9. Use of Quantitative Measurements
Consistent with the FSOC study and
the proposal, the Agencies continue to
believe that quantitative measurements
can be useful to banking entities and the
Agencies to help assess the profile of a
trading desk’s trading activity and to
help identify trading activity that may
warrant a more in-depth review.1156 The
Agencies will not use quantitative
measurements as a dispositive tool for
differentiating between permitted
market making-related activities and
prohibited proprietary trading. Like the
framework the Agencies have developed
for the market-making exemption, the
Agencies recognize that there may be
differences in the quantitative
measurements across markets and asset
classes.
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1152 See
NYSE Euronext.
1153 See Morgan Stanley.
1154 See Public Citizen.
1155 See Occupy. This commenter also stated that
the commentary in Appendix B stating that a
banking entity may give some consideration of
profitable hedging activities in determining
compensation would provide inappropriate
incentives. See id.
1156 See infra Part IV.C.3.; final rule Appendix A.
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4. Section ll.5: Permitted RiskMitigating Hedging Activities
Section ll.5 of the proposed rule
implemented section 13(d)(1)(C) of the
BHC Act, which provides an exemption
from the prohibition on proprietary
trading for certain risk-mitigating
hedging activities.1157 Section
13(d)(1)(C) provides an exemption for
risk-mitigating hedging activities in
connection with and related to
individual or aggregated positions,
contracts, or other holdings of a banking
entity that are designed to reduce the
specific risks to the banking entity in
connection with and related to such
positions, contracts, or other holdings
(the ‘‘hedging exemption’’). Section ll
.5 of the final rule implements the
hedging exemption with a number of
modifications from the proposed rule to
respond to commenters’ concerns as
described more fully below.
a. Summary of Proposal’s Approach to
Implementing the Hedging Exemption
The proposed rule would have
required seven criteria to be met in
order for a banking entity’s activity to
qualify for the hedging exemption. First,
§§ ll.5(b)(1) and ll.5(b)(2)(i) of the
proposed rule generally required that
the banking entity establish an internal
compliance program that is designed to
ensure the banking entity’s compliance
with the requirements of the hedging
limitations, including reasonably
designed written policies and
procedures, internal controls, and
independent testing, and that a
transaction for which the banking entity
is relying on the hedging exemption be
made in accordance with the
compliance program established under
§ ll.5(b)(1). Next, § ll.5(b)(2)(ii) of
the proposed rule required that the
transaction hedge or otherwise mitigate
one or more specific risks, including
market risk, counterparty or other credit
risk, currency or foreign exchange risk,
interest rate risk, basis risk, or similar
risks, arising in connection with and
related to individual or aggregated
positions, contracts, or other holdings of
the banking entity. Moreover, § ll
.5(b)(2)(iii) of the proposed rule required
that the transaction be reasonably
correlated, based upon the facts and
circumstances of the underlying and
hedging positions and the risks and
liquidity of those positions, to the risk
or risks the transaction is intended to
hedge or otherwise mitigate.
Furthermore, § ll.5(b)(2)(iv) of the
proposed rule required that the hedging
transaction not give rise, at the
1157 See 12 U.S.C. 1851(d)(1)(C); proposed rule
§ ll.5.
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5627
inception of the hedge, to significant
exposures that are not themselves
hedged in a contemporaneous
transaction. Section ll.5(b)(2)(v) of
the proposed rule required that any
hedge position established in reliance
on the hedging exemption be subject to
continuing review, monitoring and
management. Finally, § ll.5(b)(2)(vi)
of the proposed rule required that the
compensation arrangements of persons
performing the risk-mitigating hedging
activities be designed not to reward
proprietary risk-taking. Additionally,
§ ll.5(c) of the proposed rule required
the banking entity to document certain
hedging transactions at the time the
hedge is established.
b. Manner of Evaluating Compliance
With the Hedging Exemption
A number of commenters expressed
concern that the final rule required
application of the hedging exemption on
a trade-by-trade basis.1158 One
commenter argued that the text of the
proposed rule seemed to require a tradeby-trade analysis because each
‘‘purchase or sale’’ or ‘‘hedge’’ was
subject to the requirements.1159 The
final rule modifies the proposal by
generally replacing references to a
‘‘purchase or sale’’ in the § ll.5(b)
requirements with ‘‘risk-mitigating
hedging activity.’’ The Agencies believe
this approach is consistent with the
statute, which refers to ‘‘risk-mitigating
hedging activity.’’ 1160
Section 13(d)(1)(C) of the BHC Act
specifically authorizes risk-mitigating
hedging activities in connection with
and related to ‘‘individual or aggregated
positions, contracts or other
holdings.’’ 1161 Thus, the statute does
not require that exempt hedging be
conducted on a trade-by-trade basis, and
permits hedging of aggregated positions.
The Agencies recognized this in the
proposed rule, and the final rule
continues to permit hedging activities in
connection with and related to
individual or aggregated positions.
The statute also requires that, to be
exempt under section 13(d)(1)(C),
hedging activities be risk-mitigating.
The final rule incorporates this statutory
requirement. As explained in more
detail below, the final rule requires that,
in order to qualify for the exemption for
1158 See Ass’n. of Institutional Investors (Feb.
2012); See also Barclays; ICI (Feb. 2012); Investure;
MetLife; RBC; SIFMA et al. (Prop. Trading) (Feb.
2012); SIFMA (Asset Mgmt.) (Feb. 2012); Morgan
Stanley; Fixed Income Forum/Credit Roundtable;
Fidelity; FTN.
1159 See Barclays.
1160 See 12 U.S.C. 1851(d)(1)(C) (stating that ‘‘riskmitigating hedging activities’’ are permitted under
certain circumstances).
1161 See 12 U.S.C. 1851(d)(1)(C).
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risk-mitigating hedging activities: The
banking entity implement, maintain,
and enforce an internal compliance
program, including policies and
procedures that govern and control
these hedging activities; the hedging
activity be designed to reduce or
otherwise significantly mitigate and
demonstrably reduces or otherwise
significantly mitigates specific,
identifiable risks; the hedging activity
not give rise to significant new risks that
are left unhedged; the hedging activity
be subject to continuing review,
monitoring and management to address
risk that might develop over time; and
the compensation arrangements for
persons performing risk-mitigating
hedging activities be designed not to
reward or incentivize prohibited
proprietary trading. These requirements
are designed to focus the exemption on
hedging activities that are designed to
reduce risk and that also demonstrably
reduce risk, in accordance with the
requirement under section 13(d)(1)(C)
that hedging activities be risk-mitigating
to be exempt. Additionally, the final
rule imposes a documentation
requirement on certain types of hedges.
Consistent with the other exemptions
from the ban on proprietary trading for
market-making and underwriting, the
Agencies intend to evaluate whether an
activity complies with the hedging
exemption under the final rule based on
the totality of circumstances involving
the products, techniques, and strategies
used by a banking entity as part of its
hedging activity.1162
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c. Comments on the Proposed Rule and
Approach to Implementing the Hedging
Exemption
Commenters expressed a variety of
views on the proposal’s hedging
exemption. A few commenters offered
specific suggestions described more
fully below regarding how, in their
view, the hedging exemption should be
strengthened to ensure proper oversight
of hedging activities.1163 These
commenters expressed concern that the
proposal’s exemption was too broad and
argued that all proprietary trading could
be designated as a hedge under the
proposal and thereby evade the
prohibition of section 13.1164
By contrast, a number of other
commenters argued that the proposal
imposed burdensome requirements that
were not required by statute, would
limit the ability of banking entities to
1162 See
Part IV.A.4.b., infra.
e.g., AFR et al. (Feb. 2012); AFR (June
2013); Better Markets (Feb. 2012); Sens. Merkley &
Levin (Feb. 2012).
1164 See, e.g., Occupy.
1163 See,
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hedge in a prudent and cost-effective
manner, and would reduce market
liquidity.1165 These commenters argued
that implementation of the requirements
of the proposal would decrease safety
and soundness of banking entities and
the financial system by reducing costeffective risk management options.
Some commenters emphasized that the
ability of banking entities to hedge their
positions and manage risks taken in
connection with their permissible
activities is a critical element of liquid
and efficient markets, and that the
cumulative impact of the proposal
would inhibit this risk-mitigation by
raising transaction costs and
suppressing essential and beneficial
hedging activities.1166
A number of commenters expressed
concern that the proposal’s hedging
exemption did not permit the full
breadth of transactions in which
banking entities engage to hedge or
mitigate risks, such as portfolio
hedging,1167 dynamic hedging,1168
anticipatory hedging,1169 or scenario
hedging.1170 Some commenters stated
that restrictions on a banking entity’s
ability to hedge may have a chilling
effect on its willingness to engage in
other permitted activities, such as
market making.1171 In addition, many of
these commenters stated that, if a
banking entity is limited in its ability to
hedge its market-making inventory, it
may be less willing or able to assume
risk on behalf of customers or provide
financial products to customers that are
used for hedging purposes. As a result,
according to these commenters, it will
be more difficult for customers to hedge
1165 See, e.g., Australian Bankers’ Ass’n (Feb.
2012); BoA; Barclays; Credit Suisse (Seidel);
Goldman (Prop. Trading); HSBC; ICI (Feb. 2012);
Japanese Bankers Ass’n.; JPMC; Morgan Stanley;
Chamber (Feb. 2012); Wells Fargo (Prop. Trading);
Rep. Bachus et al.; RBC; SIFMA et al. (Prop.
Trading) (Feb. 2012); See also Stephen Roach.
1166 See Credit Suisse (Seidel); ICI (Feb. 2012);
Wells Fargo (Prop. Trading); See also Banco de
´
Mexico; SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); BoA.
1167 See MetLife; SIFMA et al. (Prop. Trading)
(Feb. 2012); Morgan Stanley; Barclays; Goldman
(Prop. Trading); BoA; ABA; HSBC; Fixed Income
Forum/Credit Roundtable; ICI (Feb. 2012); ISDA
(Feb. 2012).
1168 See Goldman (Prop. Trading); BoA.
1169 See Barclays; State Street (Feb. 2012); SIFMA
et al. (Prop. Trading) (Feb. 2012); Japanese Bankers
Ass’n.; Credit Suisse (Seidel); BoA; PNC et al.; ISDA
(Feb. 2012).
1170 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; Goldman (Prop. Trading); BoA; Comm. on
Capital Markets Regulation. Each of these types of
activities is discussed further below. See infra Part
IV.A.4.d.2.
1171 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); Barclays; Goldman (Prop.
Trading); BoA.
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their risks and customers may be forced
to retain risk.1172
Another commenter contended that
the proposal represented an
inappropriate ‘‘one-size-fits-all’’
approach to hedging that did not
properly take into account the way
banking entities and especially market
intermediaries operate, particularly in
less-liquid markets.1173 Two
commenters requested that the Agencies
clarify that a banking entity may use its
discretion to choose any hedging
strategy that meets the requirements of
the proposed exemption and, in
particular, that a banking entity is not
obligated to choose the ‘‘best hedge’’
and may use the cheapest instrument
available.1174 One commenter suggested
uncertainty about the permissibility of a
situation where gains on a hedge
position exceed losses on the
underlying position. The commenter
suggested that uncertainty may lead
banking entities to not use the most
cost-effective hedge, which would make
hedging less efficient and raise costs for
banking entities and customers.1175
However, another commenter expressed
concern about banking entities relying
on the cheapest satisfactory hedge. The
commenter explained that such hedges
lead to more complicated risk profiles
and require banking entities to engage in
additional transactions to hedge the
exposures resulting from the imperfect,
cheapest hedge.1176
A few commenters suggested the
hedging exemption be modified in favor
of a simpler requirement that banking
entities adopt risk limits and policies
and procedures commensurate with
qualitative guidance issued by the
Agencies.1177 Many of these
commenters also expressed concerns
that the proposed rule’s hedging
exemption would not allow so-called
asset-liability management (‘‘ALM’’)
activities.1178 Some commenters
proposed that the risk-mitigating
hedging exemption reference a set of
relevant descriptive factors rather than
1172 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Goldman (Prop. Trading); Credit Suisse (Seidel).
1173 See Barclays.
1174 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel).
1175 See SIFMA et al. (Prop. Trading) (Feb. 2012).
1176 See Occupy.
1177 See BoA; Barclays; CH/ABASA; Credit Suisse
(Seidel); HSBC; ICI (Feb. 2012); ISDA (Apr. 2012);
JPMC; Morgan Stanley; PNC; SIFMA et al. (Prop.
Trading) (Feb. 2012); See also Stephen Roach.
1178 A detailed discussion of ALM activities is
provided in Part IV.A.1.d.2 of this SUPPLEMENTARY
INFORMATION relating to the definition of trading
account. As explained in that part, the final rule
does not allow use of the hedging exemption for
ALM activities that are outside of the hedging
activities specifically permitted by the final rule.
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specific prescriptive requirements.1179
Other alternative frameworks suggested
by commenters include: (i)
Reformulating the proposed
requirements as supervisory
guidance; 1180 (ii) establishing a safe
harbor,1181 presumption of
compliance,1182 or bright line test; 1183
or (iii) a principles-based approach that
would require a banking entity to
document its risk-mitigating hedging
strategies for submission to its
regulator.1184
d. Final Rule
The final rule provides a multifaceted approach to implementing the
hedging exemption that seeks to ensure
that hedging activity is designed to be
risk-reducing in nature and not
designed to mask prohibited proprietary
trading.1185 The final rule includes a
number of modifications in response to
comments.
This multi-faceted approach is
intended to permit hedging activities
that are risk-mitigating and to limit
potential abuse of the hedging
exemption while not unduly
constraining the important riskmanagement function that is served by
a banking entity’s hedging activities.
This approach is also intended to ensure
that any banking entity relying on the
hedging exemption has in place
appropriate internal control processes to
support its compliance with the terms of
the exemption. While commenters
proposed a number of alternative
frameworks for the hedging exemption,
the Agencies believe the final rule’s
multi-faceted approach most effectively
balances commenter concerns with
statutory purpose. In response to
commenter requests to reformulate the
proposed rule as supervisory
guidance,1186 including the suggestion
that the Agencies simply require
banking entities to adopt risk limits and
policies and procedures commensurate
with qualitative Agency guidance,1187
the Agencies believe that such an
approach would provide less clarity
than the adopted approach. Although a
purely guidance-based approach could
1179 See
BoA; JPMC; Morgan Stanley.
SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; PNC et al.; ICI.
1181 See Prof. Richardson; ABA (Keating).
1182 See Barclays; BoA; ISDA (Feb. 2012).
1183 See Johnson & Prof. Stiglitz.
1184 See HSBC.
1185 See final rule § ll.5.
1186 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; PNC et al.; ICI (Feb. 2012); BoA; Morgan
Stanley.
1187 See BoA; Barclays; CH/ABASA; Credit Suisse
(Seidel); HSBC; ICI (Feb. 2012); ISDA (Apr. 2012);
JPMC; Morgan Stanley; PNC; SIFMA et al. (Prop.
Trading) (Feb. 2012); See also Stephen Roach.
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1180 See
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provide greater flexibility, it would also
provide less specificity, which could
make it difficult for banking entity
personnel and the Agencies to
determine whether an activity complies
with the rule and could lead to an
increased risk of evasion of the statutory
requirements. Further, while a brightline or safe harbor approach to the
hedging exemption would generally
provide a high degree of certainty about
whether an activity qualifies for the
exemption, it would also provide less
flexibility to recognize the differences in
hedging activity across markets and
asset classes.1188 In addition, the use of
any bright-line approach would more
likely be subject to gaming and
avoidance as new products and types of
trading activities are developed than
other approaches to implementing the
hedging exemption. Similarly, the
Agencies decline to establish a
presumption of compliance because, in
light of the constant innovation of
trading activities and the differences in
hedging activity across markets and
asset classes, establishing appropriate
parameters for a presumption of
compliance with the hedging exemption
would potentially be less capable of
recognizing these legitimate differences
than our current approach.1189
Moreover, the Agencies decline to
follow a principles-based approach
requiring a banking entity to document
its hedging strategies for submission to
its regulator.1190 The Agencies believe
that evaluating each banking entity’s
trading activity based on an
individualized set of documented
hedging strategies could be
unnecessarily burdensome and result in
unintended competitive impacts since
banking entities would not be subject to
one uniform rule. The Agencies believe
the multi-faceted approach adopted in
the final rule establishes a consistent
framework applicable to all banking
entities that will reduce the potential for
such adverse impacts.
Further, the Agencies believe the
scope of the final hedging exemption is
appropriate because it permits riskmitigating hedging activities, as
mandated by section 13 of the BHC
Act,1191 while requiring a robust
1188 Some commenters requested that the
Agencies establish a safe harbor. See Prof.
Richardson; ABA (Keating). One commenter
requested that the Agencies adopt a bright-line test.
See Johnson & Prof. Stiglitz.
1189 A few commenters requested that the
Agencies establish a presumption of compliance.
See Barclays; BoA; ISDA (Feb. 2012).
1190 One commenter suggested this principlesbased approach. See HSBC.
1191 Section 13(d)(1)(C) of the BHC Act permits
‘‘risk-mitigating hedging activities in connection
with and related to individual or aggregated
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5629
compliance program and other internal
controls to help ensure that only
genuine risk-mitigating hedges can be
used in reliance on the exemption.1192
In response to concerns that the
proposed hedging exemption would
reduce legitimate hedging activity and
thus impact market liquidity and the
banking entity’s willingness to engage in
permissible customer-related
activity,1193 the Agencies note that the
requirements of the final hedging
exemption are designed to permit
banking entities to properly mitigate
specific risk exposures, consistent with
the statute. In addition, hedging related
to market-making activity conducted by
a market-making desk is subject to the
requirements of the market-making
exemption, which are designed to
permit banking entities to continue
providing valuable intermediation and
liquidity services, including related
risk-management activity.1194 Thus, the
final hedging exemption will not
negatively impact the safety and
soundness of banking entities or the
financial system or have a chilling effect
on a banking entity’s willingness to
engage in other permitted activities,
such as market making.1195
These limits and requirements are
designed to prevent the type of activity
conducted by banking entities in the
past that involved taking large positions
using novel strategies to attempt to
profit from potential effects of general
economic or market developments and
thereby potentially offset the general
effects of those events on the revenues
or profits of the banking entity. The
documentation requirements in the final
rule support these limits by identifying
activity that occurs in reliance on the
risk-mitigating hedging exemption at an
organizational level or desk that is not
responsible for establishing the risk or
positions being hedged.
positions, contracts, or other holdings of a banking
entity that are designed to reduce the specific risks
to the banking entity in connection with and related
to such positions, contracts, or other holdings.’’ 12
U.S.C. 1851(d)(1)(C).
1192 Some commenters were concerned that the
proposed hedging exemption was too broad and
that all proprietary trading could be designated as
a hedge. See, e.g., Occupy.
1193 See, e.g., Australian Bankers Ass’n. (Feb.
2012).; BoA; Barclays; Credit Suisse (Seidel);
Goldman (Prop. Trading); HSBC; Japanese Bankers
Ass’n.; JPMC; Morgan Stanley; Chamber (Feb.
2012); Wells Fargo (Prop. Trading); Rep. Bachus et
al.; RBC; SIFMA et al. (Prop. Trading) (Feb. 2012).
1194 See supra Part IV.A.3.c.4.
1195 Some commenters believed that restrictions
on hedging would have a chilling effect on banking
entities’ willingness to engage in market making,
and may result in customers experiencing difficulty
in hedging their risks or force customers to retain
risk. See SIFMA et al. (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); Barclays; Goldman (Prop.
Trading); BoA; IHS.
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1. Compliance Program Requirement
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The first criterion of the proposed
hedging exemption required a banking
entity to establish an internal
compliance program designed to ensure
the banking entity’s compliance with
the requirements of the hedging
exemption and conduct its hedging
activities in compliance with that
program. While the compliance program
under the proposal was expected to be
appropriate for the size, scope, and
complexity of each banking entity’s
activities and structure, the proposal
would have required each banking
entity with significant trading activities
to implement robust, detailed hedging
policies and procedures and related
internal controls and independent
testing designed to prevent prohibited
proprietary trading in the context of
permitted hedging activity.1196 These
enhanced programs for banking entities
with large trading activity were
expected to include written hedging
policies at the trading unit level and
clearly articulated trader mandates for
each trader designed to ensure that
hedging strategies mitigated risk and
were not for the purpose of engaging in
prohibited proprietary trading.
Commenters, including industry
groups, generally expressed support for
requiring policies and procedures to
monitor the safety and soundness, as
well as appropriateness, of hedging
activity.1197 Some of these commenters
advocated that the final rule presume
that a banking entity is in compliance
with the hedging exemption if the
banking entity’s hedging activity is done
in accordance with the written policies
and procedures required under its
compliance program.1198 One
commenter represented that the
proposed compliance framework was
burdensome and complex.1199
Other commenters expressed
concerns that the hedging exemption
would be too limiting and burdensome
for community and regional banks.1200
Some commenters argued that foreign
banking entities should not be subject to
the requirements of the hedging
exemption for transactions that do not
introduce risk into the U.S. financial
1196 These aspects of the compliance program
requirement are described in further detail in Part
IV.C. of this SUPPLEMENTARY INFORMATION.
1197 See SIFMA et al. (Prop. Trading) (Feb. 2012).
1198 See BoA; Barclays; HSBC; JPMC; Morgan
Stanley; See also Goldman (Prop. Trading); RBC;
Barclays; ICI (Feb. 2012); ISDA (Apr. 2012); PNC;
SIFMA et al. (Prop. Trading) (Feb. 2012). See the
discussion of why the Agencies decline to take a
presumption of compliance approach above.
1199 See Barclays.
1200 See ICBA; M&T Bank.
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system.1201 Other commenters stated
that coordinated hedging through and
by affiliates should qualify as permitted
risk-mitigating hedging activity.1202
Some commenters urged the Agencies
to adopt detailed limitations on hedging
activities. For example, one commenter
urged that all hedging trades be labeled
as such at the inception of the trade and
detailed information regarding the
trader, manager, and supervisor
authorizing the trade be kept and
reviewed.1203 Another commenter
suggested that the hedging exemption
contain a requirement that the banking
entity employee who approves a hedge
affirmatively certify that the hedge
conforms to the requirements of the rule
and has not been put in place for the
direct or indirect purpose or effect of
generating speculative profits.1204 A few
commenters requested limitations on
instruments that can be used for
hedging purposes.1205
The final rule retains the proposal’s
requirement that a banking entity
establish an internal compliance
program that is designed to ensure the
banking entity limits its hedging
activities to hedging that is riskmitigating.1206 The final rule largely
retains the proposal’s approach to the
compliance program requirement,
except to the extent that, as requested by
some commenters,1207 the final rule
modifies the proposal to provide
additional detail regarding the elements
that must be included in a compliance
program. Similar to the proposal, the
final rule contemplates that the scope
and detail of a compliance program will
reflect the size, activities, and
complexity of banking entities in order
to ensure that banking entities engaged
in more active trading have enhanced
compliance programs without imposing
undue burden on smaller organizations
and entities that engage in little or no
1201 See, e.g., Bank of Canada; Allen & Overy (on
behalf of Canadian Banks). Additionally, foreign
banking entities engaged in hedging activity may be
able to rely on the exemption for trading activity
conducted by foreign banking entities in lieu of the
hedging exemption, provided they meet the
requirements of the exemption for trading by
foreign banking entities under § ll.6(e) of the
final rule. See infra Part IV.A.8.
1202 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC.
1203 See Sens. Merkley & Levin (Feb. 2012).
1204 See Better Markets (Feb. 2012).
1205 See Sens. Merkley & Levin (Feb. 2012);
Occupy; Andrea Psoras.
1206 See final rule § ll.5(b)(1). The final rule
retains the proposal’s requirement that the
compliance program include, among other things,
written hedging policies.
1207 See, e.g., BoA; ICI (Feb. 2012); ISDA (Feb.
2012); JPMC; Morgan Stanley; PNC; SIFMA et al.
(Prop. Trading) (Feb. 2012).
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trading activity.1208 The final rule also
requires, like the proposal, that the
banking entity implement, maintain,
and enforce the program.1209
In response to commenter concerns
about ensuring the appropriate level of
senior management involvement in
establishing these policies,1210 the final
rule requires that the written policies
and procedures be developed and
implemented by a banking entity at the
appropriate level of organization and
expressly address the banking entity’s
requirements for escalation procedures,
supervision, and governance related to
hedging activities.1211
Like the proposal, the final rule
specifies that a banking entity’s
compliance regime must include
reasonably designed written policies
and procedures regarding the positions,
techniques and strategies that may be
used for hedging, including
documentation indicating what
positions, contracts or other holdings a
trading desk may use in its riskmitigating hedging activities.1212 The
1208 See final rule § ll.20(a) (stating that ‘‘[t]he
terms, scope and detail of [the] compliance program
shall be appropriate for the types, size, scope and
complexity of activities and business structure of
the banking entity’’). The Agencies believe this
helps address some commenters’ concern that the
hedging exemption would be too limiting and
burdensome for community and regional banks. See
ICBA; M&T Bank.
1209 Many of these policies and procedures were
contained as part of the proposed rule’s compliance
program requirements under Appendix C. They
have been moved, and in some cases modified, in
order to more clearly demonstrate how they are
incorporated into the requirements of the hedging
exemption.
1210 See Better Markets (Feb. 2012). The final rule
does not require affirmative certification of each
hedge, as suggested by this commenter, because the
Agencies believe it would unnecessarily slow
legitimate transactions. The Agencies believe the
final rule’s required management framework and
escalation procedures achieve the same objective as
the commenter’s suggested approach, while
imposing fewer burdens on legitimate riskmitigating hedging activity.
1211 See final rule §§ ll.20(b), ll.5(b). This
approach builds on the proposal’s requirement that
senior management and intermediate managers be
accountable for the effective implementation of the
compliance program.
1212 This approach is generally consistent with
some commenters’ suggested approach of limiting
the instruments that can be used for hedging
purposes; although the final rules provide banking
entities with discretion to determine the types of
positions, contracts, or other holdings that will
mitigate specific risks of individual or aggregated
holdings and thus may be used for risk-mitigating
hedging activity. See Sens. Merkley & Levin (Feb.
2012); Occupy; Andrea Psoras. In response to one
commenter’s request that the final rule require all
hedges to be labeled at inception and certain
detailed information be documented for each hedge,
the Agencies note that the final rules continue to
require detailed documentation for hedging activity
that presents a heightened risk of evasion. See Sens.
Merkley & Levin (Feb. 2012); final rule § ll.5(c);
infra Part IV.A.4.d.4. The Agencies believe a
documentation requirement targeted at these
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focus on policies and procedures
governing risk identification and
mitigation, analysis and testing of
position limits and hedging strategies,
and internal controls and ongoing
monitoring is expected to limit use of
the hedging exception to risk-mitigating
hedging. The final rule adds to the
proposed compliance program approach
by requiring that the banking entity’s
written policies and procedures include
position and aging limits with respect to
such positions, contracts, or other
holdings.1213 The final rule, similar to
the proposed rule, also requires that the
compliance program contain internal
controls and ongoing monitoring,
management, and authorization
procedures, including relevant
escalation procedures.1214 Further, the
final rule retains the proposed
requirement that the compliance
program provide for the conduct of
analysis and independent testing
designed to ensure that the positions,
techniques, and strategies that may be
used for hedging may reasonably be
expected to demonstrably reduce or
otherwise significantly mitigate the
specific, identifiable risks being
hedged.1215
The final rule also adds that
correlation analysis be undertaken as
part of the analysis of the hedging
positions, techniques, and strategies that
may be used. This provision effectively
changes the requirement in the
proposed rule that the hedge must
maintain correlation into a requirement
that correlation be analyzed as part of
the compliance program before a
hedging activity is undertaken. This
provision incorporates the concept in
the proposed rule that a hedge should
be correlated (negatively, when sign is
considered) to the risk being hedged.
However, the Agencies recognize that
some effective hedging activities, such
as deep out-of-the-money puts and calls,
may not be exhibit a strong linear
correlation to the risks being hedged
and also that correlation over a period
of time between two financial positions
does not necessarily mean one position
scenarios balances the need to prevent evasion of
the general prohibition on proprietary trading with
the concern that documentation requirements can
slow or impede legitimate risk-mitigating activity in
the normal course.
1213 See final rule § ll.5(b)(1)(i). Some
commenters expressed support for the use of risk
limits in determining whether trading activity
qualifies for the hedging exemption. See, e.g.,
Barclays; Credit Suisse (Seidel); ICI (Feb. 2012);
Morgan Stanley.
1214 See final rule § ll.5(b)(1)(ii).
1215 See final rule § ll.5(b)(1)(iii). The final
rule’s requirement to demonstrably reduce or
otherwise significantly mitigate is discussed in
greater detail below.
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will in fact reduce or mitigate a risk of
the other. Rather, the Agencies expect
the banking entity to undertake a
correlation analysis that will, in many
but not all instances, provide a strong
indication of whether a potential
hedging position, strategy, or technique
will or will not demonstrably reduce the
risk it is designed to reduce. It is
important to recognize that the rule does
not require the banking entity to prove
correlation mathematically or by other
specific methods. Rather, the nature and
extent of the correlation analysis
undertaken would be dependent on the
facts and circumstances of the hedge
and the underlying risks targeted. If
correlation cannot be demonstrated,
then the Agencies would expect that
such analysis would explain why not
and also how the proposed hedging
position, technique, or strategy is
designed to reduce or significantly
mitigate risk and how that reduction or
mitigation can be demonstrated without
correlation.
Moreover, the final rule requires
hedging activity conducted in reliance
on the hedging exemption be subject to
continuing review, monitoring, and
management that is consistent with the
banking entity’s written hedging
policies and procedures and is designed
to reduce or otherwise significantly
mitigate, and demonstrably reduces or
otherwise significantly mitigates, the
specific, identifiable risks that develop
over time from hedging activity and
underlying positions.1216 This ongoing
review should consider market
developments, changes in positions or
the configuration of aggregated
positions, changes in counterparty risk,
and other facts and circumstances
related to the risks associated with the
underlying and hedging positions,
contracts, or other holdings.
The Agencies believe that requiring
banking entities to develop and follow
detailed compliance policies and
procedures related to risk-mitigating
hedging activity will help both banking
entities and examiners understand the
risks to which banking entities are
exposed and how these risks are
managed in a safe and sound manner.
With this increased understanding,
banking entities and examiners will be
1216 The proposal also contained a continuing
review, monitoring, and management requirement.
See proposed rule § ll.5(b)(2)(v). The final rule
modifies the proposed requirement, however, by
removing the ‘‘reasonable correlation’’ requirement
and instead requiring that the hedge demonstrably
reduce or otherwise significantly mitigate specific
identifiable risks. Correlation analysis is, however,
a necessary component of the analysis element in
the compliance program requirement of the hedging
exemption in the final rule. See final rule § ll
.5(b). This change is discussed below.
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5631
better able to evaluate whether banking
entities are engaged in legitimate, riskreducing hedging activity, rather than
impermissible proprietary trading.
While the Agencies recognize there are
certain costs associated with this
compliance program requirement,1217
we believe this provision is necessary to
ensure compliance with the statute and
the final rule. As discussed in Part
IV.C.1., the Agencies have modified the
proposed compliance program structure
to reduce burdens on small banking
entities.1218
The Agencies note that hedging may
occur across affiliates under the hedging
exemption.1219 To ensure that hedging
across trading desks or hedging done at
a level of the organization outside of the
trading desk does not result in
prohibited proprietary trading, the final
rule imposes enhanced documentation
requirements on these activities, which
are discussed more fully below. The
Agencies also note that nothing in the
final rule limits or restricts the ability of
the appropriate supervisory agency of a
banking entity to place limits on
interaffiliate hedging in a manner
consistent with their safety and
soundness authority to the extent the
agency has such authority.1220
Additionally, nothing in the final rule
limits or modifies the applicability of
CFTC regulations with respect to the
clearing of interaffiliate swaps.1221
2. Hedging of Specific Risks and
Demonstrable Reduction of Risk
Section ll.5(b)(2)(ii) of the
proposed rule required that a qualifying
transaction hedge or otherwise mitigate
one or more specific risks, including
market risk, counterparty or other credit
risk, currency or foreign exchange risk,
interest rate risk, basis risk, or similar
risks, arising in connection with and
related to individual or aggregated
positions, contracts, or other holdings of
a banking entity.1222 This criterion
1217 See
Barclays.
infra Part IV.C.1. Some commenters
expressed concern that the compliance program
requirement would place undue burden on regional
or community banks. See ICBA; M&T Bank.
1219 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC.
1220 In addition, section 608 of the Dodd-Frank
Act added credit exposure arising from securities
borrowing and lending or a derivative transaction
with an affiliate to the list of covered transactions
subject to the restrictions of section 23A of the FR
Act, in each case to the extent that such transaction
causes a bank to have credit exposure to the
affiliate. See 12 U.S.C. 371c(b)(7) and (8). As a
consequence, interaffiliate hedging activity within a
banking entity may be subject to limitation or
restriction under section 23A of the FR Act.
1221 See 17 CFR 50.52.
1222 See proposed rule § ll.5(b)(2)(ii); See also
Joint Proposal, 76 FR 68,875.
1218 See
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implemented the essential element of
the hedging exemption that the
transaction be risk-mitigating.
Some commenters expressed support
for this provision, particularly the
requirement that a banking entity be
able to tie a hedge to a specific risk.1223
One of these commenters stated that a
demonstrated reduction in risk should
be a key indicator of whether a hedge
is in fact permitted.1224 However, some
commenters argued that the list of risks
eligible to be hedged under the
proposed rule, which included risks
arising from aggregated positions, could
justify transactions that should be
viewed as prohibited proprietary
trading.1225 Another commenter
contended that the term ‘‘basis risk’’
was undefined and could heighten the
potential that this exemption would be
used to evade the prohibition on
proprietary trading.1226
Other commenters argued that
requiring a banking entity to specify the
particular risk being hedged discourages
effective hedging and increases the risk
at banking entities. These commenters
contended that hedging activities must
address constantly changing positions
and market conditions.1227 Another
commenter argued that this requirement
could render a banking entity’s hedges
impermissible if those hedges do not
succeed in fully hedging or mitigating
an identified risk as determined by a
post hoc analysis and could prevent
banking entities from entering into
hedging transactions in anticipation of
risks that the banking entity expects will
arise (or increase).1228 Certain
commenters requested that the hedging
exemption provide a safe harbor for
positions that satisfy FASB ASC Topic
815 (formerly FAS 133) hedging
accounting standards, which provides
that an entity recognize derivative
instruments, including certain
derivative instruments embedded in
other contracts, as assets or liabilities in
the statement of financial position and
measure them at fair value.1229 Another
1223 See AFR (June 2013); Sens. Merkley & Levin
(Feb. 2012); Public Citizen; Johnson & Prof. Stiglitz.
1224 See Sens. Merkley & Levin (Feb. 2012).
1225 See Public Citizen; See also Occupy.
1226 See Occupy.
1227 See, e.g., Japanese Bankers Ass’n.
1228 See Barclays.
1229 See ABA (Keating); Wells Fargo (Prop.
Trading). Although certain accounting standards,
such as FASB ASC Topic 815 hedge accounting
standards, address circumstances in which a
transaction may be considered a hedge of another
transaction, the final rule does not refer to or
expressly rely on these accounting standards
because such standards: (i) Are designed for
financial statement purposes, not to identify
proprietary trading; and (ii) change often and are
likely to change in the future without consideration
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commenter suggested that scenario
hedges could be identifiable and subject
to review by the Agencies using VaR,
Stress VaR, and VaR Exceedance, as
well as revenue metrics.1230
The Agencies have considered these
comments carefully in light of the
statute. Section 13(d)(1)(C) of the BHC
Act provides an exemption from the
prohibition on proprietary trading only
for hedging activity that is ‘‘designed to
reduce the specific risks to the banking
entity in connection with and related
to’’ individual or aggregated positions,
contracts, or other holdings of the
banking entity.1231 Thus, while the
statute permits hedging of individual or
aggregated positions (as discussed more
fully below), the statute requires that, to
be exempt from the prohibition on
proprietary trading, hedging
transactions be designed to reduce
specific risks.1232 Moreover, it requires
that these specific risks be in connection
with or related to the individual or
aggregated positions, contracts, or other
holdings of the banking entity.
The final rule implements these
requirements. To ensure that exempt
hedging activities are designed to
reduce specific risks, the final rule
requires that the hedging activity at
inception of the hedging activity,
including, without limitation, any
adjustments to the hedging activity, be
designed to reduce or otherwise
significantly mitigate and demonstrably
reduces or otherwise significantly
mitigates one or more specific,
identifiable risks, including market risk,
counterparty or other credit risk,
currency or foreign exchange risk,
interest rate risk, commodity price risk,
basis risk, or similar risks, arising in
connection with and related to
identified individual or aggregated
positions, contracts, or other holdings of
the banking entity, based upon the facts
and circumstances of the individual or
aggregated underlying and hedging
positions, contracts, or other holdings of
the banking entity and the risks and
liquidity thereof.1233 Hedging activities
and limits should be based on analysis
conducted by the banking entity of the
appropriateness of hedging instruments,
strategies, techniques, and limits. As
discussed above, this analysis must
include analysis of correlation between
of the potential impact on section 13 of the BHC
Act.
1230 See JPMC.
1231 12 U.S.C. 1851(d)(1)(C).
1232 Some commenters expressed support for the
requirement that a banking entity tie a hedge to a
specific risk. See AFR (June 2012); Sens. Merkley
& Levin (Feb. 2012); Public Citizen; Johnson & Prof.
Stiglitz.
1233 See final rule § ll.5(b)(2)(ii).
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the hedge and the specific identifiable
risk or risks that the hedge is designed
to reduce or significantly mitigate.1234
This language retains the focus of the
statute and the proposed rule on
reducing or mitigating specific and
identified risks.1235 As discussed more
fully above, banking entities are
required to describe in their compliance
policies and procedures the types of
strategies, techniques, and positions that
may be used for hedging.
The final rule does not prescribe the
hedging strategy that a banking entity
must employ. While one commenter
urged that the final rule require each
banking entity to adopt the ‘‘best hedge’’
for every transaction,1236 the Agencies
believe that the complexity of positions,
market conditions at the time of a
transaction, availability of hedging
transactions, costs of hedging, and other
circumstances at the time of the
transaction make a requirement that a
banking entity always adopt the ‘‘best
hedge’’ impractical, unworkable, and
subjective.
Nonetheless, the statute requires that,
to be exempt under section 13(d)(1)(C),
hedging activity must be risk-mitigating.
To ensure that only risk-mitigating
hedging is permitted under this
exemption, the final rule requires that in
its written policies and procedures the
banking entity identify the instruments
and positions that may be used in
hedging, the techniques and strategies
the banking entity deems appropriate
for its hedging activities, as well as
position limits and aging limits on
hedging positions. These written
policies and procedures also must
specify the escalation and approval
procedures that apply if a trader seeks
to conduct hedging activities beyond the
limits, position types, strategies, or
techniques authorized for the trader’s
activities.1237
final rule § ll.5(b)(1)(iii).
commenters represented that the
proposed list of risks eligible to be hedged could
justify transactions that should be considered
proprietary trading. See Public Citizen; Occupy.
One commenter was concerned about the proposed
inclusion of ‘‘basis risk’’ in this list. See Occupy.
As noted in the proposal, the Agencies believe the
inclusion of a list of eligible risks, including basis
risk, helps implement the essential element of the
statutory hedging exemption—i.e., that the
transaction is risk-reducing in connection with a
specific risk. See Joint Proposal, 76 FR 68,875. See
also 12 U.S.C. 1851(d)(1)(C). Further, the Agencies
believe the other requirements of the final hedging
exemption, including requirements regarding
internal controls and a compliance program, help
to ensure that only legitimate hedging activity
qualifies for the exemption.
1236 See, e.g., Occupy.
1237 A banking entity must satisfy the enhanced
documentation requirements of § ll.5(c) if it
engages in hedging activity utilizing positions,
contracts, or holdings that were not identified in its
written policies and procedures.
1234 See
1235 Some
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As noted above, commenters were
concerned that risks associated with
permitted activities and holdings
change over time, making a
determination regarding the
effectiveness of hedging activities in
reducing risk dependent on the time
when risk is measured. To address this,
the final rule requires that the exempt
hedging activity be designed to reduce
or otherwise significantly mitigate, and
demonstrably reduces or otherwise
significantly mitigates, risk at the
inception of the hedge. As explained
more fully below, because risks and the
effectiveness of a hedging strategy may
change over time, the final rule also
requires the banking entity to
implement a program to review,
monitor, and manage its hedging
activity over the period of time the
hedging activity occurs in a manner
designed to reduce or significantly
mitigate and demonstrably reduce or
otherwise significantly mitigate new or
changing risks that may develop over
time from both the banking entity’s
hedging activities and the underlying
positions. Many commenters expressed
concern that the proposed ongoing
review, monitoring, and management
requirement would limit a banking
entity’s ability to engage in aggregated
position hedging.1238 One commenter
stated that because aggregated position
hedging may result in modification of
hedging exposures across a variety of
underlying risks, even as the overall risk
profile of a banking entity is reduced, it
would become impossible to
subsequently review, monitor, and
manage individual hedging transactions
for compliance.1239 The Agencies note
that the final rule, like the statute,
requires that the hedging activity relate
to individual or aggregated positions,
contracts or other holdings being
hedged, and accordingly, the review,
monitoring and management
requirement would not limit the extent
of permitted hedging provided for in
section 13(d)(1)(C) as implied by some
commenters. Further, the final rule
recognizes that the determination of
whether hedging activity demonstrably
reduces or otherwise significantly
mitigates risks that may develop over
time should be ‘‘based upon the facts
and circumstances of the underlying
and hedging positions, contracts and
other holdings of the banking entity and
the risks and liquidity thereof.’’ 1240
1238 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Barclays; ICI (Feb. 2012); Morgan Stanley.
1239 See Barclays.
1240 Final rule § ll.5(b)(2)(iv)(B). The Agencies
believe this provision addresses some commenters’
concern that the ongoing review, monitoring, and
management requirement would limit hedging of
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A number of other commenters
argued that a legitimate risk-reducing
hedge may introduce new risks at
inception.1241 A few commenters
contended that a requirement that no
new risks be associated with a hedge
would be inconsistent with prudent risk
management and greatly reduce the
ability of banking entities to reduce
overall risk through hedging.1242 A few
commenters stated that the proposed
requirement does not recognize that it is
not always possible to hedge a new risk
exposure arising from a hedge in a costeffective manner.1243 With respect to the
timing of the initial hedge and any
additional transactions necessary to
reduce significant exposures arising
from it, one of these commenters
represented that requiring
contemporaneous hedges is
impracticable, would raise transaction
costs, and would make hedging
uneconomic.1244 Another commenter
stated that this requirement could have
a chilling effect on risk managers’
willingness to engage in otherwise
permitted hedging activity.1245
Other commenters stated that a
position that does not fully offset the
risk of an underlying position is not in
fact a hedge.1246 These commenters
believed that the introduction of new
risks at inception of a transaction
indicated that the transaction was
impermissible proprietary trading and
not a hedge.1247
The Agencies recognize that prudent
risk-reducing hedging activities by
banking entities are important to the
efficiency of the financial system.1248
The Agencies further recognize that
hedges are generally imperfect;
consequently, hedging activities can
introduce new and sometimes
significant risks, such as credit risk,
basis risk, or new market risk, especially
5633
when hedging illiquid positions.1249
However, the Agencies also recognize
that hedging activities present an
opportunity to engage in impermissible
proprietary trading designed to profit
from exposure to these types of risks.
To address these competing concerns,
the final rule substantially retains the
proposed requirement that, at the
inception of the hedging activity, the
risk-reducing hedging activity does not
give rise to significant new or additional
risk that is not itself contemporaneously
hedged. This approach is designed to
allow banking entities to continue to
engage in prudent risk-mitigating
activities while ensuring that the
hedging exemption is not used to engage
in prohibited proprietary trading by
taking on prohibited short-term
exposures under the guise of
hedging.1250 As noted in the proposal,
however, the Agencies recognize that
exposure to new risks may result from
legitimate hedging transactions; 1251 this
provision only prohibits the
introduction of additional significant
exposures through the hedging
transaction unless those additional
exposures are contemporaneously
hedged.
As noted above, the final rule
recognizes that whether hedging activity
will demonstrably reduce risk must be
based upon the facts and circumstances
of the individual or aggregated
underlying and hedging positions,
contracts, or other holdings of the
banking entity and the risks and
liquidity thereof.1252 The Agencies
believe this approach balances
commenters’ request that the Agencies
clarify that a banking entity may use its
discretion to choose any hedging
strategy that meets the requirements of
1249 See,
e.g., SIFMA et al. (Prop. Trading) (Feb.
2012).
aggregated positions, and that such ongoing review
of individual hedge transactions with a variety of
underlying risks would be impossible. See SIFMA
(Prop. Trading) (Feb. 2012); Barclays; ICI (Feb.
2012); Morgan Stanley.
1241 See ABA (Keating); BoA; Barclays; Credit
Suisse (Seidel); Goldman (Prop. Trading); SIFMA et
al. (Prop. Trading) (Feb. 2012); See also AFR et al.
(Feb. 2012).
1242 See Credit Suisse (Seidel); Goldman (Prop.
Trading); SIFMA et al. (Prop. Trading) (Feb. 2012).
1243 See SIFMA et al. (Prop. Trading) (Feb. 2012);
Barclays.
1244 See SIFMA et al. (Prop. Trading) (Feb. 2012).
1245 See BoA.
1246 See Sens. Merkley & Levin (Feb. 2012); Public
Citizen; AFR (Nov. 2012).
1247 See Better Markets (Feb. 2012); AFR et al.
(Feb. 2012).
1248 See FSOC study (stating that ‘‘[p]rudent risk
management is at the core of both institutionspecific safety and soundness, as well as
macroprudential and financial stability’’).
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1250 Some commenters stated that it is not always
possible to hedge a new risk exposure arising from
a hedge in a cost-effective manner, and requiring
contemporaneous hedges would raise transaction
costs and the potential for hedges to become
uneconomical. See SIFMA et al. (Prop. Trading)
(Feb. 2012); Barclays. As noted in the proposal, the
Agencies believe that requiring a contemporaneous
hedge of any significant new risk that arises at the
inception of a hedge is appropriate because a
transaction that creates significant new risk
exposure that is not itself hedged at the same time
would appear to be indicative of prohibited
proprietary trading. See Joint Proposal, 76 FR
68,876. Thus, the Agencies believe this requirement
is necessary to prevent evasion of the general
prohibition on proprietary trading. In response to
commenters’ concerns about transaction costs and
uneconomical hedging, the Agencies note that this
provision only requires additional hedging of
‘‘significant’’ new or additional risk and does not
apply to any risk exposure arising from a hedge.
1251 See Joint Proposal, 76 FR 68,876.
1252 See final rule § ll.5(b)(2)(ii).
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the proposed exemption 1253 with
concerns that allowing banking entities
to rely on the cheapest satisfactory
hedge will lead to additional hedging
transactions.1254 The Agencies expect
that hedging strategies and techniques,
as well as assessments of risk, will vary
across positions, markets, activities and
banking entities, and that a ‘‘one-sizefits-all’’ approach would not
accommodate all types of appropriate
hedging activity.1255
By its terms, section 13(d)(1)(C) of the
BHC Act permits a banking entity to
engage in risk-mitigating hedging
activity ‘‘in connection with and
related to individual or aggregated
positions . . . .’’ 1256 The preamble to
the proposed rule made clear that,
consistent with the statutory reference
to mitigating risks of individual or
aggregated positions, this criterion
permits hedging of risks associated with
aggregated positions.1257 This approach
is consistent with prudent riskmanagement and safe and sound
banking practice.1258
The proposed rule explained that, to
be exempt under this provision, hedging
activities must reduce risk with respect
to ‘‘positions, contracts, or other
holdings of the banking entity.’’ The
proposal also required that a banking
entity relying on the exemption be
prepared to identify the specific
position or risks associated with
aggregated positions being hedged and
demonstrate that the hedging
transaction was risk-reducing in the
aggregate, as measured by appropriate
risk management tools.
Some commenters were of the view
that the hedging exemption applied to
aggregated positions or portfolio
hedging and was consistent with
prudent risk-management practices.
These commenters argued that
permitting a banking entity to hedge
aggregate positions and risks arising
from a portfolio of assets would be more
efficient from both a procedural and
business standpoint.1259
1253 See SIFMA (Prop. Trading) (Feb. 2012);
Credit Suisse (Seidel); Barclays; Goldman (Prop.
Trading); BoA.
1254 See Occupy.
1255 See Barclays.
1256 12 U.S.C. 1851(d)(1)(C).
1257 See Joint Proposal, 76 FR 68,875.
1258 See, e.g., Australian Bankers’ Ass’n. (Feb.
2012); BoA; Barclays; Credit Suisse (Seidel);
Goldman (Prop. Trading); HSBC; ICI (Feb. 2012);
Japanese Bankers Ass’n.; JPMC; Morgan Stanley;
Wells Fargo (Prop. Trading); Rep. Bachus et al.;
RBC; SIFMA (Prop. Trading) (Feb. 2012).
1259 See, e.g. ABA (Keating); Ass’n. of
Institutional Investors (Sept. 2012); BoA; See also
Barclays (expressing concern that the proposed rule
could result in regulatory review of individual
hedging trades for compliance on a post hoc basis);
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By contrast, other commenters argued
that portfolio-based hedging could be
used to mask prohibited proprietary
trading.1260 One commenter contended
that the statute provides no basis for
portfolio hedging, and another
commenter similarly suggested that
portfolio hedging should be
prohibited.1261 Another commenter
suggested adopting limits that would
prevent the use of the hedging
exemption to conduct proprietary
activity at one desk as a theoretical
‘‘hedge for proprietary trading at
another desk.’’ 1262 Among the limits
suggested by these commenters were a
requirement that a banking entity have
a well-defined compliance program, the
formation of central ‘‘risk management’’
groups to perform and monitor hedges
of aggregated positions, and a
requirement that the banking entity
demonstrate the capacity to measure
aggregate risk across the institution with
precision using proven models.1263 A
few commenters suggested that the
presence of portfolio hedging should be
viewed as an indicator of imperfections
in hedging at the desk level and be a flag
used by examiners to identify and
review the integrity of specific
hedges.1264
The final rule, like the proposed rule,
implements the statutory language
providing for risk-mitigating hedging
activities related to individual or
aggregated positions. For example,
activity permitted under the hedging
exemption would include the hedging
of one or more specific risks arising
from identified positions, contracts, or
other holdings, such as the hedging of
the aggregate risk of identified positions
of one or more trading desks. Further,
the final rule requires that these hedging
activities be risk-reducing with respect
to the identified positions, contracts, or
other holdings being hedged and that
the risk reduction be demonstrable.
Specifically, the final rule requires,
among other things: That the banking
entity has a robust compliance program
reasonably designed to ensure
HSBC; ISDA (Apr. 2012); ICI (Feb. 2012); PNC;
MetLife; RBC; SIFMA (Prop. Trading) (Feb. 2012).
1260 See, e.g., AFR et al. (Feb. 2012); Sens.
Merkley & Levin (Feb. 2012); Occupy; Public
Citizen; Johnson & Prof. Stiglitz.
1261 See Sens. Merkley & Levin (Feb. 2012)
(commenting that the use of the term ‘‘aggregate’’
positions was intended to note that firms do not
have to hedge on a trade-by-trade basis but could
not hedge on a portfolio basis); Johnson & Prof.
Stiglitz.
1262 See AFR et al. (Feb. 2012) (citing 156 Cong.
Rec. S5898 (daily ed. July 15, 2010) (statement of
Sen. Merkley)).
1263 See, e.g., Occupy; Public Citizen.
1264 See Public Citizen; Occupy; AFR et al. (Feb.
2012).
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compliance with the exemption; that
each hedge is subject to continuing
review, monitoring and management
designed to demonstrably reduce or
otherwise significantly mitigate the
specific, identifiable risks that develop
over time related to the hedging activity
and the underlying positions, contracts,
or other holdings of the banking entity;
and that the banking entity meet a
documentation requirement for hedges
not established by the trading desk
responsible for the underlying position
or for hedges effected through a
financial instrument, technique or
strategy that is not specifically
identified in the trading desk’s written
policies and procedures. The Agencies
believe this approach addresses
concerns that a banking entity could use
the hedging exemption to conduct
proprietary activity at one desk as a
theoretical hedge for proprietary trading
at another desk in a manner consistent
with the statute.1265 Further, the
Agencies believe the adopted exemption
allows banking entities to engage in
hedging of aggregated positions 1266
while helping to ensure that such
hedging activities are truly riskmitigating.1267
As noted above, several commenters
questioned whether the hedging
exemption should apply to ‘‘portfolio’’
hedging and whether portfolio hedging
may create the potential for abuse of the
hedging exemption. The term ‘‘portfolio
hedging’’ is not used in the statute. The
language of section 13(d)(1)(C) of the
BHC Act permits a banking entity to
engage in risk-mitigating hedging
activity ‘‘in connection with and related
to individual or aggregated positions .
. . .’’ 1268 After consideration of the
comments regarding portfolio hedging,
and in light of the statutory language,
the Agencies are of the view that the
statutory language is clear on its face
that a banking entity may engage in riskmitigating hedging in connection with
aggregated positions of the banking
entity. The permitted hedging activity,
when involving more than one position,
contract, or other holding, must be in
1265 See AFR et al. (Feb. 2012) (citing 156 Cong.
Rec. S5898 (daily ed. July 15, 2010) (statement of
Sen. Merkley)).
1266 See MetLife; SIFMA et al. (Prop. Trading)
(Feb. 2012); Morgan Stanley; Barclays; Goldman
(Prop. Trading); BoA; ABA (Keating); HSBC; Fixed
Income Forum/Credit Roundtable; ICI (Feb. 2012);
ISDA (Feb. 2012).
1267 The Agencies believe certain limits suggested
by commenters, such as the formation of central
‘‘risk management’’ groups to monitor hedges of
aggregated positions, are unnecessary given the
aforementioned limits in the final rule. See Occupy;
Public Citizen.
1268 See 12 U.S.C. 1851(d)(1)(C).
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connection with or related to aggregated
positions of the banking entity.
Moreover, hedging of aggregated
positions under this exemption must be
related to identifiable risks related to
specific positions, contracts, or other
holdings of the banking entity. Hedging
activity must mitigate one or more
specific risks arising from an identified
position or aggregation of positions. The
risks in this context are not intended to
be more generalized risks that a trading
desk or combination of desks, or the
banking entity as a whole, believe exists
based on non-position-specific
modeling or other considerations. For
example, the hedging activity cannot be
designed to: Reduce risks associated
with the banking entity’s assets and/or
liabilities generally, general market
movements or broad economic
conditions; profit in the case of a
general economic downturn;
counterbalance revenue declines
generally; or otherwise arbitrage market
imbalances unrelated to the risks
resulting from the positions lawfully
held by the banking entity.1269 Rather,
the hedging exemption permits the
banking entity to engage in trading
activity designed to reduce or otherwise
mitigate specific, identifiable risks
related to identified individual or
aggregated positions that the banking
entity it otherwise lawfully permitted to
have.
When undertaking a hedge to mitigate
the risk of an aggregation of positions,
the banking entity must be able to
specifically identify the risk factors
arising from this set of positions. In
identifying the aggregate set of positions
that is being hedged for purposes of
§ ll.5(b)(2)(ii) and, where applicable,
§ ll.5(c)(2)(i), the banking entity
needs to identify the positions being
hedged with sufficient specificity so
that at any point in time, the specific
financial instrument positions or
components of financial instrument
positions held by the banking entity that
comprise the set of positions being
hedged can be clearly identified.
The proposal would have permitted a
series of hedging transactions designed
to rebalance hedging position(s) based
on changes resulting from permissible
activities or from a change in the price
or other characteristic of the individual
or aggregated positions, contracts, or
other holdings being hedged.1270 The
1269 The Agencies believe that it would be
inconsistent with Congressional intent to permit
some or all of these activities under the hedging
exemption, regardless of whether certain metrics
could be useful for monitoring such activity. See
JPMC.
1270 See proposed rule § ll.5(b)(2)(ii) (requiring
that the hedging transaction ‘‘hedges or otherwise
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Agencies recognized that, in such
dynamic hedging, material changes in
risk may require a corresponding
modification to the banking entity’s
current hedge positions.1271
Some commenters questioned the
risk-mitigating nature of a hedge if, at
inception, that hedge contained
component risks that must be
dynamically managed throughout the
life of the hedge. These commenters
stated that hedges that do not
continuously match the risk of
underlying positions are not in fact riskmitigating hedges in the first place.1272
On the other hand, other commenters
argued that banking entities must be
permitted to engage in dynamic hedging
activity, such as in response to market
conditions which are unforeseeable or
out of the control of the banking
entity,1273 and expressed concern that
the limitations of the proposed rule,
especially the requirement that hedging
transactions ‘‘maintain a reasonable
level of correlation,’’ might impede truly
risk-reducing hedging activity.1274
A number of commenters asserted
that there could be confusion over the
meaning of ‘‘reasonable correlation,’’
which was used in the proposal as part
of explaining what type of activity
would qualify for the hedging
exemption. Some commenters urged
requiring that there be a ‘‘high’’ or
‘‘strong’’ correlation between the hedge
and the risk of the underlying asset.1275
Other commenters indicated that
uncertainty about the meaning of
reasonable correlation could limit valid
risk-mitigating hedging activities
because the level of correlation between
a hedge and the risk of the position or
aggregated positions being hedged
changes over time as a result of changes
in market factors and conditions.1276
mitigates one or more specific risks . . . arising in
connection with and related to individual or
aggregated positions, contracts, or other holdings of
[the] banking entity’’). The proposal noted that this
requirement would include, for example, dynamic
hedging. See Joint Proposal, 76 FR 68,875.
1271 The proposal noted that this corresponding
modification to the hedge should also be reasonably
correlated to the material changes in risk that are
intended to be hedged or otherwise mitigated, as
required by § ll.5(b)(2)(iii) of the proposed rule.
1272 See AFR et al. (Feb. 2012); Public Citizen; See
also Better Markets (Feb. 2012), Sens. Merkley &
Levin (Feb. 2012).
1273 See Japanese Bankers Ass’n.
1274 See, e.g., BoA; Barclays; ISDA (Apr. 2012);
PNC; PNC et al.; SIFMA et al. (Prop. Trading) (Feb.
2012).
1275 See, e.g., Occupy; Public Citizen; AFR et. al.
(Feb. 2012); AFR (June 2013); Better Markets (Feb.
2012); Sens. Merkley & Levin (Feb. 2012).
1276 See BoA; Barclays; Comm. on Capital Markets
Regulation; Credit Suisse (Seidel); FTN; Goldman
(Prop. Trading); ICI (Feb. 2012); Japanese Bankers
Ass’n.; JPMC; Morgan Stanley; SIFMA et al. (Prop.
Trading) (Feb. 2012); STANY; See also Chamber
(Feb. 2012).
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Some commenters represented that the
proposed provision would cause certain
administrative burdens 1277 or may
result in a reduction in market-making
activities in certain asset classes.1278 A
few commenters expressed concern that
the reasonable correlation requirement
could render a banking entity’s hedges
impermissible if they do not succeed in
being reasonably correlated to the
relevant risk or risks based on an afterthe-fact analysis that incorporates
market developments that could not
have been foreseen at the time the hedge
was placed. These commenters tended
to favor a different approach or a type
of safe harbor based on an initial
determination of correlation.1279 Some
commenters argued the focus of the
hedging exemption should be on risk
reduction and not on reasonable
correlation.1280 One commenter
suggested that risk management metrics
such as VaR and risk factor sensitivities
could be the focus for permitted hedging
instead of requirements like reasonable
correlation under the proposal.1281
In consideration of commenter
concerns about the proposed reasonable
correlation requirement, the final rule
modifies the proposal in the following
key respects. First, the final rule
modifies the requirement of ‘‘reasonable
correlation’’ by providing that the hedge
demonstrably reduce or otherwise
significantly mitigate specific
identifiable risks.1282 This change is
1277 See Japanese Bankers Ass’n.; Goldman (Prop.
Trading); BoA.
1278 See BoA; SIFMA (Asset Mgmt.) (Feb. 2012).
As discussed above, market-maker hedging at the
trading desk level is no longer subject to the
hedging exemption and is instead subject to the
requirements of the market-making exemption,
which is designed to permit banking entities to
continue providing legitimate market-making
services, including managing the risk of marketmaking activity. See also supra Part IV.A.3.c.4. of
this SUPPLEMENTARY INFORMATION.
1279 See Barclays; Goldman (Prop. Trading);
Chamber (Feb. 2012); SIFMA et al. (Prop. Trading)
(Feb. 2012); See also FTN; BoA.
1280 See, e.g., FTN; Goldman (Prop. Trading);
ISDA (Apr. 2012); See also Sens. Merkley & Levin
(Feb. 2012); Occupy.
1281 See Goldman (Prop. Trading). Consistent
with the FSOC study and the proposal, the
Agencies continue to believe that quantitative
measurements can be useful to banking entities and
the Agencies to help assess the profile of a trading
desk’s trading activity and to help identify trading
activity that may warrant a more in-depth review.
See infra Part IV.C.3.; final rule Appendix A. The
Agencies do not intend to use quantitative
measurements as a dispositive tool for
differentiating between permitted hedging activities
and prohibited proprietary trading.
1282 Some commenters stated that the hedging
exemption should focus on risk reduction, not
reasonable correlation. See, e.g., FTN; Goldman
(Prop. Trading); ISDA (Apr. 2012); Sens. Merkley &
Levin (Feb. 2012); Occupy. One of these
commenters noted that demonstrated risk reduction
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designed to reinforce that hedging
activity should be demonstrably risk
reducing or mitigating rather than
simply correlated to risk. This change
acknowledges that hedges need not
simply be correlated to underlying
positions, and that hedging activities
should be consciously designed to
reduce or mitigate identifiable risks, not
simply the result of pairing correlated
positions, as some commenters
suggested.1283 As discussed above, the
Agencies do, however, recognize that
correlation is often a critical element of
demonstrating that a hedging activity
reduces the risks it is designed to
address. Accordingly, the final rule
requires that banking entities conduct
correlation analysis as part of the
required compliance program in order
to utilize the hedging exemption.1284
The Agencies believe this change better
allows consideration of the facts and
circumstances of the particular hedging
activity as part of the correlation
analysis and therefore addresses
commenters’ concerns that the proposed
reasonable correlation requirement
could cause administrative burdens,
impede legitimate hedging activity,1285
and require an after-the-fact
analysis.1286
Second, the final rule provides that
the determination of whether an activity
or strategy is risk-reducing or mitigating
must, in the first instance, be made at
the inception of the hedging activity. A
trade that is not risk-reducing at its
inception is not viewed as a hedge for
purposes of the exemption in § ll
.5.1287
Third, the final rule requires that the
banking entity conduct analysis and
independent testing designed to ensure
that the positions, techniques, and
strategies used for hedging are
reasonably designed to reduce or
should be a key requirement. See Sens. Merkley &
Levin (Feb. 2012).
1283 See FTN; Goldman (Prop. Trading); ISDA
(Apr. 2012); See also Sens. Merkley & Levin (Feb.
2012); Occupy.
1284 See final rule § ll.5(b)(1)(iii).
1285 Some commenters expressed concern that the
proposed ‘‘reasonable correlation’’ requirement
might impede truly risk-reducing activity. See, e.g.,
BoA; Barclays; Comm. on Capital Markets
Regulation; Credit Suisse (Seidel); FTN; Goldman
(Prop. Trading); ICI (Feb. 2012); ISDA (Apr. 2012);
Japanese Bankers Ass’n.; JPMC; Morgan Stanley;
PNC; PNC et al.; SIFMA et al. (Prop. Trading) (Feb.
2012); STANY. Some of these commenters stated
that the proposed requirement would cause
administrative burdens. See Japanese Bankers
Ass’n.; Goldman (Prop. Trading); BoA.
1286 See Barclays; Goldman (Prop. Trading);
Chamber (Feb. 2012); SIFMA et al. (Prop. Trading)
(Feb. 2012; See also FTN.
1287 By contrast, the proposed requirement did
not specify that the hedging activity reduce risk ‘‘at
the inception of the hedge.’’ See proposed rule
§ ll.5(b)(2)(ii).
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otherwise mitigate the risk being
hedged. As noted above, such analysis
and testing must include correlation
analysis. Evidence of negative
correlation may be a strong indicator
that a given hedging position or strategy
is risk-reducing. Moreover, positive
correlation, in some instances, may be
an indicator that a hedging position or
strategy is not designed to be riskmitigating. The type of analysis and
factors considered in the analysis
should take account of the facts and
circumstances, including type of
position being hedged, market
conditions, depth and liquidity of the
market for the underlying and hedging
position, and type of risk being hedged.
The Agencies recognize that markets
and risks are dynamic and that the risks
from a permissible position or
aggregated positions may change over
time, new risks may emerge in the
positions underlying the hedge and in
the hedging position, new risks may
emerge from the hedging strategy over
time, and hedges may become less
effective over time in addressing the
related risk.1288 The final rule, like the
proposal, continues to allow dynamic
hedging. Additionally, the final rule
requires the banking entity to engage in
ongoing review, monitoring, and
management of its positions and related
hedging activity to reduce or otherwise
significantly mitigate the risks that
develop over time. This ongoing
hedging activity must be designed to
reduce or otherwise significantly
mitigate, and must demonstrably reduce
or otherwise significantly mitigate, the
material changes in risk that develop
over time from the positions, contracts,
or other holdings intended to be hedged
or otherwise mitigated in the same way,
as required for the initial hedging
activity. Moreover, the banking entity is
required under the final rule to support
its decisions regarding appropriate
hedging positions, strategies and
techniques for its ongoing hedging
activity in the same manner as for its
initial hedging activities. In this
manner, the final rule permits a banking
entity to engage in effective
management of its risks throughout
changing market conditions 1289 while
1288 Some
commenters noted that hedging
activities must address constantly changing
positions and market conditions and expressed
concern about requiring a banking entity to identify
the particular risk being hedged. See Japanese
Bankers Ass’n.; Barclays.
1289 A few commenters expressed concern that
the proposed ‘‘reasonable correlation’’ requirement
would render hedges impermissible if not
reasonably correlated to the relevant risk(s) based
on a post hoc analysis. See, e.g., Barclays; Goldman
(Prop. Trading); Chamber (Feb. 2012); SIFMA et al.
(Prop. Trading) (Feb. 2012).
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also seeking to prohibit the banking
entity from taking large proprietary
positions through action or inaction
related to an otherwise permissible
hedge.1290
As explained above, the final rule
requires a banking entity relying on the
hedging exemption to be able to
demonstrate that the banking entity is
exposed to the specific risks being
hedged at the inception of the hedge
and any adjustments thereto. However,
in the proposal, the Agencies requested
comment on whether the hedging
exemption should be available in
certain cases where hedging activity
begins before the banking entity
becomes exposed to the underlying risk.
The Agencies proposed that the hedging
exemption would be available in certain
cases where the hedge is established
‘‘slightly’’ before the banking entity
becomes exposed to the underlying risk
if such anticipatory hedging activity: (i)
Was consistent with appropriate risk
management practices; (ii) otherwise
met the terms of the hedging exemption;
and (iii) did not involve the potential for
speculative profit. For example, a
banking entity that was contractually
obligated or otherwise highly likely to
become exposed to a particular risk
could engage in hedging that risk in
advance of actual exposure.1291
A number of commenters argued that
anticipatory hedging is a necessary and
prudent activity and that the final rule
should permit anticipatory hedging
more broadly than did the proposed
rule.1292 In particular, commenters were
concerned that permitting hedging
activity only if it occurs ‘‘slightly’’
before a risk is taken could limit
hedging activities that are crucial to risk
management.1293 Commenters
expressed concern that the proposed
approach would, among other things,
make it difficult for banking entities to
accommodate customer requests for
transactions with specific price or size
executions 1294 and limit dynamic
hedging activities that are important to
sound risk management.1295 In addition,
a number of commenters requested that
the rule permit banking entities to
engage in scenario hedging, a form of
1290 Some commenters questioned the riskmitigating nature of a hedge if, at inception, it
contained risks that must be dynamically managed
throughout the life of the hedge. See, e.g., AFR et
al. (Feb. 2012); Public Citizen.
1291 See Joint Proposal, 76 FR 68,875.
1292 See, e.g., Barclays; SIFMA et al. (Prop.
Trading); Japanese Bankers Ass’n.; Credit Suisse
(Seidel); BoA; PNC et al.; ISDA (Feb. 2012).
1293 See BoA; Credit Suisse (Seidel); ISDA (Feb.
2012); JPMC; Morgan Stanley; PNC et al.; SIFMA et
al. (Prop. Trading) (Feb. 2012).
1294 See Credit Suisse (Seidel); BoA.
1295 See PNC et al.
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anticipatory hedging that addresses
potential exposures to ‘‘tail risks.’’1296
Some commenters expressed concern
about the proposed criterion that the
hedging activity not involve the
potential for speculative profit.1297
These commenters argued that the
proper focus of the hedging exemption
should be on the purpose of the
transaction, and whether the hedge is
correlated to the underlying risks being
hedged (in other words, whether the
hedge is effective in mitigating risk).1298
By contrast, another commenter urged
the Agencies to adopt a specific metric
to track realized profits on hedging
activities as an indicator of prohibited
arbitrage trading.1299
Like the proposal, the final rule does
not prohibit anticipatory hedging.
However, in response to commenter
concerns that the proposal would limit
a banking entity’s ability to respond to
customer requests and engage in
prudent risk management, the final rule
does not retain the proposed
requirement discussed above that an
anticipatory hedge be established
‘‘slightly’’ before the banking entity
becomes exposed to the underlying risk
and meet certain conditions. To address
commenter concerns with the statutory
mandate, several parts of the final rule
are designed to ensure that all hedging
activities, including anticipatory
hedging activities, are designed to be
risk reducing and not impermissible
proprietary trading activities. For
example, the final rule retains the
proposed requirement that a banking
entity have reasonably designed policies
1296 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; Goldman (Prop. Trading); BoA; Comm. on
Capital Market Regulation. As discussed above,
hedging activity relying on this exemption cannot
be designed to: Reduce risks associated with the
banking entity’s assets and/or liabilities generally,
general market movements or broad economic
conditions; profit in the case of a general economic
downturn; counterbalance revenue declines
generally; or otherwise arbitrage market imbalances
unrelated to the risks resulting from the positions
lawfully held by the banking entity.
1297 See ABA (Keating); CH/ABASA; See also
Credit Suisse (Seidel); PNC; PNC et al.; SIFMA et
al. (Prop. Trading) (Feb. 2012). One commenter
argued that anticipatory hedging should not be
permitted because it represents illegal front
running. See Occupy. The Agencies note that not
all anticipatory hedging would constitute illegal
front running. Any activity that is illegal under
another provision of law, such as front running
under section 10(b) of the Exchange Act, remains
illegal; and section 13 of the BHC Act and any
implementing rules thereunder do not represent a
grant of authority to engage in any such activity.
See 15 U.S.C. 78j.
1298 As discussed above, the final hedging
exemption replaces the ‘‘reasonable correlation’’
concept with the requirement that hedging activity
‘‘demonstrably reduce or otherwise significantly
mitigate’’ specific, identifiable risks.
1299 See AFR et al. (Feb. 2012); See also Part
IV.C.3.d., infra.
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and procedures indicating the positions,
techniques and strategies that each
trading desk may use for hedging. These
policies and procedures should
specifically address when anticipatory
hedging is appropriate and what
policies and procedures apply to
anticipatory hedging.
The final rule also requires that a
banking entity relying on the hedging
exemption be able to demonstrate that
the hedging activity is designed to
reduce or significantly mitigate, and
does demonstrably reduce or otherwise
significantly mitigate, specific,
identifiable risks in connection with
individual or aggregated positions of the
banking entity.1300 Importantly, to use
the hedging exemption, the final rule
requires that the banking entity subject
its hedging activity to continuing
review, monitoring, and management
that is designed to reduce or
significantly mitigate specific,
identifiable risks, and that demonstrably
reduces or otherwise significantly
mitigates identifiable risks, in
connection with individual or
aggregated positions of the banking
entity.1301 The final rule also requires
ongoing recalibration of the hedging
activity by the banking entity to ensure
that the hedging activity satisfies the
requirements set out in § ll.5(b)(2)
and is not prohibited proprietary
trading. If an anticipated risk does not
materialize within a limited time period
contemplated when the hedge is entered
into, under these provisions, the
banking entity would be required to
extinguish the anticipatory hedge or
otherwise demonstrably reduce the risk
associated with that position as soon as
reasonably practicable after it is
determined that the anticipated risk will
not materialize. This requirement
focuses on the purpose of the hedge as
a trade designed to reduce anticipated
risk and not for other purposes. The
Agencies will (and expect that banking
entities also will) monitor the activities
of banking entities to identify prohibited
1300 This requirement modifies proposed rule
§§ ll.5(b)(2)(ii) and (iii). As discussed above, the
addition of ‘‘demonstrably reduces or significantly
mitigates’’ language replaces the proposed
‘‘reasonable correlation’’ requirement.
1301 The proposed rule contained a similar
provision, except that the proposed provision also
required that the continuing review maintain a
reasonable level of correlation between the hedge
transaction and the risk being hedged. See proposed
rule § ll.5(b)(2)(v). As discussed above, the
proposed ‘‘reasonable correlation’’ requirement was
removed from that provision and instead a
requirement has been added to the compliance
program provision that correlation analysis be
undertaken when analyzing hedging positions,
techniques, and strategies before they are
implemented.
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trading activity that is disguised as
anticipatory hedging.
As noted above, one commenter
suggested the Agencies adopt a metric to
monitor the profitability of a banking
entity’s hedging activity.1302 We are not
adopting such a metric because we do
not believe it would be useful to
monitor the profit and loss associated
with hedging activity in isolation
without considering the profit and loss
associated with the individual or
aggregated positions being hedged. For
example, the commenter’s suggested
metric would not appear to provide
information about whether the gains
arising from hedging positions offset or
mitigate losses from individual or
aggregated positions being hedged.
3. Compensation
The proposed rule required that the
compensation arrangements of persons
performing risk-mitigating hedging
activities be designed not to reward
proprietary risk-taking.1303 In the
proposal, the Agencies stated that
hedging activities for which a banking
entity has established a compensation
incentive structure that rewards
speculation in, and appreciation of, the
market value of a covered financial
position, rather than success in reducing
risk, are inconsistent with permitted
risk-mitigating hedging activities.1304
Commenters generally supported this
requirement and indicated that its
inclusion was very important and
valuable.1305 Some commenters argued
that the final rule should limit
compensation based on profits derived
from hedging transactions, even if those
hedging transactions were in fact riskmitigating hedges, and urged that
employees be compensated instead
based on success in risk mitigation at
the end of the life of the hedge.1306 In
contrast, other commenters argued that
the compensation requirement should
restrict only compensation
arrangements that incentivize
employees to engage in prohibited
proprietary risk-taking.1307
After considering comments received
on the compensation requirements of
the proposed hedging exemption, the
final rule substantially retains the
proposed requirement that the
compensation arrangements of persons
performing risk-mitigating hedging
activities be designed not to reward
prohibited proprietary trading. The final
1302 See
AFR et al. (Feb. 2012).
proposed rule § ll.5(b)(2)(vi).
1304 See Joint Proposal, 76 FR 68,868.
1305 See, e.g., AFR et al. (Feb. 2012); Sens.
Merkley & Levin (Feb. 2012); Public Citizen.
1306 See AFR et al. (Feb. 2012); AFR (June 2013).
1307 See Morgan Stanley.
1303 See
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rule is also modified to make clear that
rewarding or incentivizing profit
making from prohibited proprietary
trading is not permitted.1308
The Agencies recognize that
compensation, especially incentive
compensation, may be both an
important motivator for employees as
well as a useful indicator of the type of
activity that an employee or trading
desk is engaged in. For instance, an
incentive compensation plan that
rewards an employee engaged in
activities under the hedging exemption
based primarily on whether that
employee’s positions appreciate in
value instead of whether such positions
reduce or mitigate risk would appear to
be designed to reward prohibited
proprietary trading rather than riskreducing hedging activities.1309
Similarly, a compensation arrangement
that is designed to incentivize an
employee to exceed the potential losses
associated with the risks of the
underlying position rather than reduce
risks of underlying positions would
appear to reward prohibited proprietary
trading rather than risk-mitigating
hedging activities. The banking entity
should review its compensation
arrangements in light of the guidance
and rules imposed by the appropriate
Federal supervisor for the entity
regarding compensation.1310
4. Documentation Requirement
Section ll.5(c) of the proposed rule
would have imposed a documentation
requirement on certain types of hedging
transactions. Specifically, for any
transaction that a banking entity
conducts in reliance on the hedging
exemption that involved a hedge
established at a level of organization
different than the level of organization
establishing or responsible for the
positions, contracts, or other holdings
the risks of which the hedging
transaction is designed to reduce, the
banking entity was required, at a
minimum, to document: the riskmitigating purpose of the transaction;
the risks of the individual or aggregated
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1308 One
commenter stated that the compensation
requirement should restrict only compensation
arrangements that incentivize employees to engage
in prohibited proprietary risk-taking, rather than
apply to hedging activities. See Morgan Stanley.
1309 Thus, the Agencies agree with one
commenter who stated that compensation for
hedging should not be based purely on profits
derived from hedging. However, the final rule does
not require compensation vesting, as suggested by
this commenter, because the Agencies believe the
final hedging exemption includes sufficient
requirements to ensure that only risk-mitigating
hedging is permitted under the exemption without
a compensation vesting provision. See AFR et al.
(Feb. 2012); AFR (June 2013).
1310 See 12 U.S.C. 5641.
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positions, contracts, or other holdings of
a banking entity that the transaction is
designed to reduce; and the level of
organization that is establishing the
hedge.1311 Such documentation was
required to be established at the time
the hedging transaction is effected. The
Agencies expressed concern in the
proposal that hedging transactions
established at a different level of
organization than the positions being
hedged may present or reflect
heightened potential for prohibited
proprietary trading, either at the trading
desk level or at the level instituting the
hedging transaction. In other words, the
further removed hedging activities are
from the specific positions, contracts, or
other holdings the banking entity
intends to hedge, the greater the danger
that such activity is not limited to
hedging specific risks of individual or
aggregated positions, contracts, or other
holdings of the banking entity, as
required by the rule.
Some commenters argued that the
final rule should require comprehensive
documentation for all activity
conducted pursuant to the hedging
exemption, regardless of where it occurs
in an organization.1312 One of these
commenters stated that such
documentation can be easily and
quickly produced by traders and noted
that traders already record execution
details of every trade.1313 Several
commenters argued that the rule should
impose a requirement that banks label
all hedges at their inception and provide
information regarding the specific risk
being offset, the expected duration of
the hedge, how it will be monitored,
how it will be wound down, and the
names of the trader, manager, and
supervisor approving the hedge.1314
Some commenters requested that the
documentation requirement be applied
at a higher level of organization,1315 and
some commenters noted that policies
and procedures alone would be
sufficient to address hedging activity,
wherever conducted within the
organization.1316 Two commenters
1311 For example, as explained under the
proposal, a hedge would be established at a
different level of organization of the banking entity
if multiple market-making desks were exposed to
similar risks and, to hedge such risks, a hedge was
established at the direction of a supervisor or risk
manager responsible for more than one desk rather
than at each of the market-making desks that
established the initial positions, contracts, or other
holdings. See Joint Proposal, 76 FR 68,876 n.161.
1312 See AFR (June 2013); Occupy.
1313 See Occupy.
1314 See Sens. Merkley & Levin (Feb. 2012);
Occupy; AFR (June 2013).
1315 See SIFMA et al. (Prop. Trading) (Feb. 2012);
JPMC; Barclays; See also Japanese Bankers Ass’n.
1316 See JPMC; SIFMA et al. (Prop. Trading) (Feb.
2012).
PO 00000
Frm 00104
Fmt 4701
Sfmt 4700
indicated that making the
documentation requirement narrower is
necessary to avoid impacts or delays in
daily trading operations that could lead
to a banking entity being exposed to
greater risks.1317 A number of
commenters stated that any enhanced
documentation requirement would be
burdensome and costly, and would
impede rapid and effective risk
mitigation, whether done at a trading
desk or elsewhere in the banking
entity.1318
At least one commenter also argued
that a banking entity should be
permitted to consolidate some or all of
its hedging activity into a trading desk
that is not responsible for the
underlying positions without triggering
a requirement that all hedges
undertaken by a trading desk be
documented solely because the hedges
are not undertaken by the trading desk
that originated the underlying
position.1319
The final rule substantially retains the
proposed requirement for enhanced
documentation for hedging activity
conducted under the hedging exemption
if the hedging is not conducted by the
specific trading desk establishing or
responsible for the underlying positions,
contracts, or other holdings, the risks of
which the hedging activity is designed
to reduce. The final rule clarifies that a
banking entity must prepare enhanced
documentation if a trading desk
establishes a hedging position and is not
the trading desk that established the
underlying positions, contracts, or other
holdings. The final rule also requires
enhanced documentation for hedges
established to hedge aggregated
positions across two or more desks. This
change in the final rule clarifies that the
level of the organization at which the
trading desk exists is important for
determining whether the trading desk
established or is responsible for the
underlying positions, contracts, or other
holdings. The final rule recognizes that
a trading desk may be responsible for
hedging aggregated positions of that
desk and other desks, business units, or
affiliates. In that case, the trading desk
putting on the hedge is at least one step
removed from some of the positions
being hedged. Accordingly, the final
rule provides that the documentation
requirements in § ll.5 apply if a
trading desk is hedging aggregated
positions that include positions from
more than one trading desk.
1317 See
JPMC; Barclays.
Barclays; JPMC; SIFMA et al. (Prop.
Trading) (Feb. 2012); See also Japanese Bankers
Ass’n.
1319 See JPMC.
1318 See
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The final rule adds to the proposal by
requiring enhanced documentation for
hedges established by the specific
trading desk establishing or directly
responsible for the underlying positions,
contracts, or other holdings, the risks of
which the purchases or sales are
designed to reduce, if the hedge is
effected through a financial instrument,
technique, or strategy that is not
specifically identified in the trading
desk’s written policies and procedures
as a product, instrument, exposure,
technique, or strategy that the trading
desk may use for hedging.1320 The
Agencies note that this documentation
requirement does not apply to hedging
activity conducted by a trading desk in
connection with the market makingrelated activities of that desk or by a
trading desk that conducts hedging
activities related to the other
permissible trading activities of that
desk so long as the hedging activity is
conducted in accordance with the
compliance program for that trading
desk.
The Agencies continue to believe that,
for the reasons stated in the proposal, it
is appropriate to retain documentation
of hedging transactions conducted by
those other than the traders responsible
for the underlying position in order to
permit evaluation of the activity. In
order to reduce the burden of the
documentation requirement while still
giving effect to the rule’s purpose, the
final rule requires limited
documentation for hedging activity that
is subject to a documentation
requirement, consisting of: (1) The
specific, identifiable risk(s) of the
identified positions, contracts, or other
holdings that the purchase or sale is
designed to reduce; (2) the specific riskmitigating strategy that the purchase or
sale is designed to fulfill; and (3) the
trading desk or other business unit that
is establishing and responsible for the
hedge transaction. As in the proposal,
this documentation must be established
contemporaneously with the hedging
transaction. Documentation would be
contemporaneous if it is completed
reasonably promptly after a trade is
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1320 One
commenter suggested that the rule
require documentation when a banking entity needs
to engage in new types of hedging transactions that
are not covered by its hedging policies, although
this commenter’s suggested approach would only
apply when a hedge is conducted two levels above
the level at which the risk arose. See SIFMA et al.
(Prop. Trading) (Feb. 2012). The Agencies agree that
documentation is needed when a trading desk is
acting outside of its hedging policies and
procedures. However, the final rule does not limit
this documentation requirement to circumstances
when the hedge is conducted two organizational
levels above the trading desk. Such an approach
would be less effective than the adopted approach
at addressing evasion concerns.
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executed. The banking entity is required
to retain records for no less than 5 years
(or such longer period as may be
required under other law) in a form that
allows the banking entity to promptly
produce such records to the Agency on
request.1321 While the Agencies
recognize this documentation
requirement may result in certain costs,
the Agencies believe this requirement is
necessary to prevent evasion of the
statute and final rule.
5. Section ll.6(a)–(b): Permitted
Trading in Certain Government and
Municipal Obligations
Section ll.6 of the proposed rule
permitted a banking entity to engage in
trading activities that were authorized
by section 13(d)(1) of the BHC Act,1322
including trading in certain government
obligations, trading on behalf of
customers, trading by insurance
companies, and trading outside of the
United States by certain foreign banking
entities.1323 Section ll.6 of the final
rule generally incorporates these same
statutory exemptions. However, the
final rule has been modified in some
ways in response to comments received
on the proposal.
a. Permitted Trading in U.S.
Government Obligations
Section 13(d)(1)(A) permits trading in
various U.S. government, U.S. agency
and municipal securities.1324 Section
ll.6(a) of the proposed rule, which
implemented section 13(d)(1)(A) of the
BHC Act, permitted the purchase or sale
of a financial instrument that is an
obligation of the United States or any
agency thereof or an obligation,
participation, or other instrument of or
issued by the Government National
Mortgage Association, the Federal
National Mortgage Association, the
Federal Home Loan Mortgage
Corporation, a Federal Home Loan
Bank, the Federal Agricultural Mortgage
Corporation or a Farm Credit System
institution chartered under and subject
to the provisions of the Farm Credit Act
of 1971 (12 U.S.C. 2001 et seq.).1325 The
final rule § ll5(c)(3).
proposed rule § ll.6.
1323 See 12 U.S.C. 1851(d)(1)(A), (C), (F), and (H).
1324 12 U.S.C. 1851(d)(1)(A).
1325 The Agencies proposed that United States
‘‘agencies’’ for this purpose would include those
agencies described in section 201.108(b) of the
Board’s Regulation A. See 12 CFR 201.108(b). The
Agencies also noted that the terms of the exemption
would encompass the purchase or sale of
enumerated government obligations on a forward
basis (e.g., in a to-be-announced market). In
addition, this would include pass-through or
participation certificates that are issued and
guaranteed by a government-sponsored entity (e.g.,
the Federal National Mortgage Association and the
1321 See
1322 See
PO 00000
Frm 00105
Fmt 4701
Sfmt 4700
5639
proposal did not contain an exemption
for trading in derivatives referencing
exempt U.S. government and agency
securities, but requested comment on
whether the final rule should contain an
exemption for proprietary trading in
options or other derivatives referencing
an exempt government obligation.1326
Commenters were generally
supportive of the manner in which the
proposal implemented the exemption
for permitted trading in U.S.
government and U.S. agency
obligations.1327 Many commenters
argued that the exemption for
permissible proprietary trading in
government obligations should be
expanded, however, to include trading
in derivatives on government
obligations.1328 These commenters
asserted that failure to provide an
exemption would adversely impact
liquidity in the underlying government
obligations themselves and increase
borrowing costs to governments.1329
Several commenters asserted that U.S.
government and agency obligations and
derivatives on those instruments are
substitutes and pose the same
investment risks and opportunities.1330
According to some commenters, the
significant connections between these
markets and the interchangeable nature
of these instruments significantly
contribute to price discovery, in
particular, in the cash market for U.S.
Treasury obligations.1331 Commenters
also argued that trading in Treasury
futures and options improves liquidity
in Treasury securities markets by
providing an outlet to relieve any
supply and demand imbalances in spot
obligations. Many commenters argued
that the authority to engage in trading in
derivatives on U.S. government, agency,
and municipal obligations is inherent in
the statutory exceptions granted by
section 13(d)(1)(A) to trade in the
underlying obligation.1332 To the extent
there is any doubt about the scope of
those exemptions, commenters urged
the Agencies to use the exemptive
Federal Home Loan Mortgage Corporation) in
connection with its securitization activities.
1326 See Joint Proposal, 76 FR 68,878.
1327 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012); Sens. Merkley & Levin (Feb. 2012).
1328 See BoA; CalPERS; Credit Suisse (Seidel);
CME Group; Fixed Income Forum/Credit
Roundtable; FIA; JPMC; Morgan Stanley; PNC;
SIFMA et al. (Prop. Trading) (Feb. 2012); Wells
Fargo (Prop. Trading).
1329 See BoA; FIA; HSBC; JPMC; Morgan Stanley;
Wells Fargo (Prop. Trading).
1330 See Barclays; Credit Suisse (Seidel); Fixed
Income Forum/Credit Roundtable; FIA.
1331 See Barclays; CME Group; Fixed Income
Forum/Credit Roundtable; See also UBS.
1332 See CME Group; See also Morgan Stanley;
PNC; SIFMA et al. (Prop. Trading) (Feb. 2012);
Wells Fargo (Prop. Trading).
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authority under section 13(d)(1)(J) if
necessary to permit proprietary trading
in derivatives on government
obligations.1333 Two commenters
opposed providing an exemption for
proprietary trading in derivatives on
exempt government obligations.1334
The final rule has not been modified
to permit a banking entity to engage in
proprietary trading of derivatives on
U.S. government and agency
obligations.
The Agencies note that the cash
market for exempt government
obligations is already one of the most
liquid markets in the world, and the
final rule will permit banking entities to
participate fully in these cash markets.
In addition, the final rule permits
banking entities to make a market in
U.S. government securities and in
derivatives on those securities.
Moreover, the final rule allows banking
entities to continue to use U.S.
government obligations and derivatives
on those obligations in risk-mitigating
hedging activities permitted by the rule.
Further, proprietary trading in
derivatives on such obligations will
continue by entities other than banking
entities.
Proprietary trading of derivatives on
U.S. government obligations is not
necessary to promote and protect the
safety and soundness of a banking entity
or the financial stability of the United
States. Commenters offered no
compelling reasons why derivatives on
exempt government obligations pose
little or no risk to the financial system
as compared to derivatives on other
financial products for which proprietary
trading is generally prohibited and did
not indicate how proprietary trading in
derivatives of U.S. government and
agency obligations by banking entities
would promote the safety and
soundness of those entities or the
financial stability of the United States.
For these reasons, the Agencies have not
determined to provide an exemption for
proprietary trading in derivatives on
exempt government obligations.
The Agencies believe banking entities
will continue to provide significant
support and liquidity to the U.S.
government and agency security
markets through permitted trading in
the cash exempt government obligations
markets, making markets in government
obligation derivatives and through
derivatives trading for hedging
purposes. The final rule adopts the same
approach as the proposed rule for the
exemption for permitted trading in U.S.
government and U.S. agency
1333 See
1334 See
Barclays; CME Group; JPMC.
Occupy; Alfred Brock.
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obligations. In response to commenters,
the Agencies are clarifying how banking
entities would be permitted to use
Treasury derivatives on Treasury
securities when relying on the
exemptions for market-making related
activities and risk-mitigating hedging
activities. The Agencies agree with
commenters that some Treasury
derivatives are close economic
substitutes for Treasury securities and
provide many of the same economic
exposures.1335 The Agencies also
understand that the markets for
Treasury securities and Treasury futures
are fully integrated, and that trading in
these derivative instruments is essential
to ensuring the continued smooth
functioning of market-making related
activities in Treasury securities.
Treasury derivatives are frequently used
by market makers to hedge their marketmaking related positions across many
different types of fixed-income
securities. Under the final rule, market
makers will generally be able to
continue their practice of using
Treasury futures to hedge their activities
as block positioners off exchanges.
Additionally, when engaging in
permitted market-making related or riskmitigating hedging activities in
accordance with the requirements in
§§ ll.4(b) or ll.(5), the final rule
permits banking entities to acquire a
short or long position in Treasury
futures through manual trading or
automated processes. For example, a
banking entity would be permitted to
use Treasury futures to hedge the
duration risk (i.e., the measure of a
bond’s price sensitivity to interest rates
movements) associated with the banking
entity’s market-making in Treasury
securities or other fixed-income
products, provided that the banking
entity complies with the market-making
requirements in § ll.4(b). In their
market making, banking entities also
frequently trade Treasury futures (and
acquire a corresponding long or short
position) in reasonable anticipation of
the near-term demands of their clients,
customers, and counterparties. For
example, banking entities may acquire a
long or short position in Treasury
futures to hedge anticipated market risk
when they reasonably expect clients,
customers, or counterparties will seek to
establish long or short positions in onor off-the-run Treasury securities.
Similarly, banking entities could
acquire a long or short position in the
‘‘Treasury basis’’ to hedge the
anticipated basis risk associated with
making markets for clients, customers,
or counterparties that are reasonably
1335 See
PO 00000
infra note 1330.
Frm 00106
Fmt 4701
Sfmt 4700
expected to engage in basis trading of
the price spread between Treasury
futures and Treasury securities. A
banking entity can also use Treasury
futures (or other derivatives on exempt
government obligations) to hedge other
risks such as the aggregated interest rate
risk for specifically identified loans as
well as other financial instruments such
as asset-backed securities, corporate
bonds, and interest rate swaps.
Therefore, depending on the relevant
facts and circumstances, banking
entities would be permitted to acquire a
very large long or short position in
Treasury derivatives provided that they
comply with the requirements in
§§ ll.4(b) or ll.(5). The Agencies
also understand that banking entities
that have been designated as ‘‘primary
dealers’’ by the Federal Reserve Bank of
New York are required to underwrite
issuances of Treasury securities. This
necessitates the banking entities to
frequently establish very large short
positions in Treasury futures to order to
hedge the duration risk associated with
potentially owning a large volume of
Treasury securities. As described
below,1336 the Agencies note that, with
respect to a banking entity that acts as
a primary dealer for Treasury securities,
the U.S. government will be considered
a client, customer, or counterparty of
the banking entity for purposes of the
market-making exemption.1337 We
believe this interpretation appropriately
captures the unique relationship
between a primary dealer and the
government. Moreover, this
interpretation clarifies that a banking
entity may rely on the market-making
exemption for its activities as primary
dealer to the extent those activities are
outside the scope of the underwriting
exemption.1338
The final rule also includes an
exemption for obligations of or
guaranteed by the United States or an
agency of the United States. An
obligation guaranteed by the U.S. or an
agency of the U.S. is, in effect, an
obligation of the U.S. or that agency.
The final rule also includes an
exemption for an obligation of the FDIC,
or any entity formed by or on behalf of
the FDIC for the purpose of facilitating
the disposal of assets acquired or held
by the FDIC in its corporate capacity or
as conservator or receiver under the
Federal Deposit Insurance Act (‘‘FDI
Act’’) or Title II of the Dodd-Frank
1336 See
infra Part IV.A.3.c.2.c.i.
supra note 905 (explaining the functions
of primary dealers).
1338 See supra Part IV.A.3.c.2.b.ix. (discussing
commenters’ concerns regarding primary dealer
activity, as well as one commenter’s request for
such an interpretation).
1337 See
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Act.1339 These FDIC receivership and
conservatorship operations are
authorized under the FDI Act and Title
II of the Dodd-Frank Act and are
designed to lower the FDIC’s resolution
costs. The Agencies believe that an
exemption for these types of obligations
would promote and protect the safety
and soundness of banking entities and
the financial stability of the United
States because they facilitate the FDIC’s
ability to conduct receivership and
conservatorship operations in an orderly
manner, thereby limiting risks to the
financial system generally that might
otherwise occur if the FDIC was
restricted in its ability to conduct these
operations.
b. Permitted Trading in Foreign
Government Obligations
The proposed rule did not contain an
exemption for trading in obligations of
foreign sovereign entities. As part of the
proposal, however, the Agencies
specifically requested comment on
whether proprietary trading in the
obligations of foreign governments
would promote and protect the safety
and soundness of banking entities and
the financial stability of the United
States under section 13(d)(1)(J) of the
BHC Act.1340
The treatment of proprietary trading
in foreign sovereign obligations
prompted a significant number of
comments. Many commenters,
including foreign governments, foreign
and domestic banking entities, and
various trade groups, argued that the
final rule should permit trading in
foreign sovereign debt, including
obligations issued by political
subdivisions of foreign governments.1341
Representatives from foreign
governments such as Canada, Germany,
Luxembourg, Japan, Australia, and
Mexico specifically requested an
exemption for trading in obligations of
their governments and argued that an
exemption was necessary and
appropriate to maintain and promote
final rule § ll.6(a)(4).
Joint Proposal, 76 FR 68,878.
1341 See, e.g., Allen & Overy (Gov’t Obligations);
Allen & Overy (Canadian Banks); BoA; Australian
Bankers Ass’n. (Feb. 2012); AFMA; Banco de
´
Mexico; Bank of Canada; Ass’n of German Banks;
BAROC; Barclays; BEC (citing the National Institute
of Banking and Finance); British Bankers’ Ass’n.;
BaFin/Deutsche Bundesbank; Chamber (Feb. 2012);
Mexican Banking Comm’n.; French Treasury et al.;
EFAMA; ECOFIN; EBF; French Banking Fed’n.;
FSA (Apr. 2012); FIA; Goldman (Prop. Trading);
HSBC; Hong Kong Inv. Funds Association; IIB/EBF;
ICFR; ICSA; IRSG; Japanese Bankers Ass’n.; Ass’n.
of Banks in Malaysia; OSFI; British Columbia;
´
Quebec; Sumitomo Trust; TMA Hong Kong; UBS;
Union Asset.
1339 See
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financial stability in their markets.1342
Some commenters also requested an
exemption for trading in obligations of
multinational central banks, such as
Eurobonds issued or guaranteed by the
European Central Bank.1343
Many commenters argued that the
same rationale for the statutory
exemption for proprietary trading in
U.S. government obligations supported
exempting proprietary trading in foreign
sovereign debt and related
obligations.1344 Commenters contended
that lack of an express exemption for
trading in foreign sovereign obligations
could critically impact the functioning
of money market operations of foreign
central banks and limit the ability of
foreign sovereign governments to
conduct monetary policy or finance
their operations.1345 These commenters
also contended that an exemption for
proprietary trading in foreign sovereign
debt would promote and protect the
safety and soundness and the financial
stability of the United States by
avoiding the possible negative effects of
a contraction of government bond
market liquidity.1346
Commenters also contended that in
some foreign markets, local regulations
or market practice require U.S. banking
entities operating in those jurisdictions
to hold, trade or support government
issuance of local sovereign securities.
They also indicated that these
instruments are traded in the United
States or on U.S. markets.1347 In
addition, a number of commenters
contended that U.S. and foreign banking
entities often perform functions for
1342 See, e.g., Allen & Overy (Gov’t Obligations);
Bank of Canada; British Columbia; Ontario; IIAC;
Quebec; IRSG; IIB/EBF; Mitsubishi; Gov’t of Japan/
Bank of Japan; Australian Bankers Ass’n (Feb.
´
2012); AFMA; Banco de Mexico; Ass’n. of German
Banks; ALFI; Embassy of Switzerland.
1343 See Ass’n. of German Banks; Goldman (Prop.
Trading); IIB/EBF; ICFR; FIA; Mitsubishi;
Sumitomo Trust; Allen & Overy (Gov’t Obligations).
1344 See Allen & Overy (Gov’t. Obligations); Banco
´
de Mexico; Barclays; BaFIN/Deutsche Bundesbank;
EFAMA; Union Asset; TMA Hong Kong; ICI (Feb.
2012) (arguing that such an exemption would be
consistent with Congressional intent to limit the
extra-territorial application of U.S. law).
1345 See Banco de Mexico; Barclays; BoA; Gov’t of
´
Japan/Bank of Japan; IIAC; OSFI.
1346 See, e.g., Allen & Overy (Gov’t. Obligations);
´
AFMA; Banco de Mexico; Ass’n. of German Banks;
Barclays; Mexican Banking Comm’n.; EFAMA; EBF;
French Banking Fed’n.; Goldman (Prop. Trading);
HSBC; IIB/EBF; HSBC; ICSA; T. Rowe Price; UBS;
Union Asset; IRSG; EBF; Mitsubishi (citing Japanese
Bankers Ass’n. and IIB); Wells Fargo (Prop.
Trading); ICI Global.
1347 See Allen & Overy (Gov’t. Obligations)
(contending that ‘‘even if not primary dealers,
banking entities or their branches or agencies acting
in certain foreign jurisdictions, such as Singapore
and India, are still required to hold or transact in
local sovereign debt under local law’’); BoA;
Barclays; Citigroup; SIFMA et al. (Prop. Trading)
(Feb. 2012).
PO 00000
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Fmt 4701
Sfmt 4700
5641
foreign governments similar to those
provided in the United States by U.S.
primary dealers and alleged that
restricting these trading activities would
have a significant negative impact on
the ability of foreign governments to
implement their monetary policy and on
liquidity for such securities in many
foreign markets.1348 A few commenters
further argued that banking entities use
foreign sovereign debt, particularly debt
of their home country and of the
country in which they are operating, to
manage their risk by posting sovereign
securities as collateral in foreign
jurisdictions, to manage international
rate and foreign exchange risk
(particularly in local operations), and
for liquidity and asset-liability
management purposes in different
countries.1349 Similarly, commenters
expressed concern that the lack of an
exemption for trading in foreign
government obligations could adversely
interact with other banking regulations,
such as liquidity requirements under
the Basel III capital rules that encourage
financial institutions to hold large
concentrations of sovereign bonds to
match foreign currency denominated
obligations.1350 Commenters also
expressed particular concern that the
limitations and obligations of section 13
of the BHC Act would likely be
problematic and unduly burdensome if
banking entities were able to trade in
foreign sovereign obligations only under
the market making or other proposed
exemptions from the proprietary trading
prohibition.1351 One commenter
expressed the view that lack of an
exemption for proprietary trading in
foreign government obligations together
with the proposed exemption for trading
that occurs solely outside the U.S. may
cause foreign banks to close their U.S.
branches to avoid being subject to
section 13 of the BHC Act and any final
rule thereunder.1352
1348 See Allen & Overy (Gov’t. Obligations);
Australian Bankers Ass’n. (Feb. 2012); BoA; Banco
´
de Mexico; Barclays; Citigroup; Goldman (Prop.
Trading); IIB/EBF; See also JPMC (suggesting that,
at a minimum, the Agencies should make clear that
all of a firm’s activities that are necessary or
reasonably incidental to its acting as a primary
dealer in a foreign government’s debt securities are
protected by the market-making-related permitted
activity); SIFMA et al. (Prop. Trading) (Feb. 2012).
As discussed in Parts IV.A.2.c.2.c. and
IV.A.2.c.2.b.ix of this SUPPLEMENTARY INFORMATION,
the Agencies believe primary dealing activities
would generally qualify under the scope of the
market-making or underwriting exemption.
1349 See Citigroup; SIFMA et al. (Prop. Trading)
(Feb. 2012).
1350 See Allen & Overy (Gov’t. Obligations); BoA.
1351 See Barclays; IIAC; UBS; Ass’n. of Banks in
Malaysia; IIB/EBF.
1352 See Comm. on Capital Markets Regulation.
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According to some commenters,
providing an exemption only for
proprietary trading in U.S. government
obligations, without a similar exemption
for foreign government obligations,
would be discriminatory and
inconsistent with longstanding
principles of national treatment and
with U.S. treaty obligations, such as
obligations under the World Trade
Organization framework or bilateral
trade agreements.1353 In addition,
several commenters argued that not
exempting proprietary trading of foreign
sovereign debt may encourage foreign
regulators to enact similar regulations to
the detriment of U.S. financial
institutions operating abroad.1354
However, another commenter disagreed
that the failure to exempt trading in
foreign government obligations would
violate trade agreements or that the
proposal discriminated in any way
against foreign banking entities’ ability
to compete with U.S. banking entities in
the U.S.1355
Based on these concerns, some
commenters suggested that the Agencies
exempt proprietary trading by foreign
banking entities in obligations of their
home or host country.1356 Other
commenters suggested allowing trading
in foreign government obligations that
meet some condition on quality (e.g.,
OECD-member country obligations,
government bonds eligible as collateral
for Federal Reserve advances, sovereign
bonds issued by G–20 countries, or
other highly liquid or rated
instruments).1357 One commenter
indicated that in their view, provided
appropriate risk-management
procedures are followed, investing in
non-U.S. government securities is as
low risk as investing in U.S. government
securities despite current price volatility
in certain types of sovereign debt.1358
Some commenters also suggested the
final rule give deference to home
country regulation and permit foreign
banking entities to engage in proprietary
trading in any government obligation to
1353 See Allen & Overy (Gov’t. Obligations); Banco
´
de Mexico; IIB/EBF; Ass’n. of Banks in Malaysia.
1354 See Sumitomo Trust; SIFMA et al. (Prop.
Trading) (Feb. 2012); Allen & Overy (Govt.
Obligations); BoA; ICI Global; RBC; ICFR; ICI (Feb.
2012); Bank of Canada; Cadwalader (on behalf of
Singapore Banks); Ass’n. of Banks in Malaysia;
Cadwalader (on behalf of Thai Banks); Chamber
(Feb. 2012); BAROC. See also IIB/EBF.
1355 See Sens. Merkley &Levin (Feb. 2012).
1356 See Cadwalader (on behalf of Thai Banks);
IIB/EBF; Ass’n. of Banks in Malaysia; UBS; See also
BAROC.
1357 See BoA; Cadwalader (on behalf of Singapore
Banks); IIB/EBF; Norinchukin; OSFI; Cadwalader
(on behalf of Thai Banks); Ass’n. of Banks in
Malaysia; UBS; See also BAROC; ICFR; Japanese
´
Bankers Ass’n.; JPMC; Quebec.
1358 See, e.g., Allen & Overy (Gov’t Obligations).
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the extent that such trading is permitted
by the entity’s primary regulator.1359
By contrast, other commenters argued
that proprietary trading in foreign
sovereign obligations represents a risky
activity and that there is no effective
way to draw the line between safe and
unsafe foreign debt.1360 Two of these
commenters pointed to several publicly
reported instances where proprietary
trading in foreign sovereign obligations
resulted in significant losses to certain
firms. These commenters argued that
restricting proprietary trading in foreign
sovereign debt would not cause reduced
liquidity in government bond markets
since banking entities would still be
permitted to make a market in and
underwrite foreign government
obligations.1361 A few commenters
suggested that, if the final rule
exempted proprietary trading in foreign
sovereign debt, foreign governments
should commit to pay for any damage to
the U.S. financial system related to
proprietary trading in their obligations
pursuant to such exemption.1362
The Agencies carefully considered all
the comments related to proprietary
trading in foreign sovereign debt in light
of the language, purpose and standards
for exempting activity contained in
section 13 of the BHC Act. Under
section 13(d)(1)(J), the Agencies may
grant an exemption from the
prohibitions of the section for any
activity that the Agencies determine
would promote and protect the safety
and soundness of the banking entity and
the financial stability of the United
States.
The Agencies note as an initial matter
that section 13 permits banking
entities—both inside the United States
and outside the United States—to make
markets in and to underwrite all types
of securities, including all types of
foreign sovereign debt. The final rule
implements the statutory market-making
and underwriting exemptions, and thus,
the key role of banking entities in
facilitating trading and liquidity in
foreign government debt through
market-making and underwriting is
maintained. This includes underwriting
and marketmaking as a primary dealer
in foreign sovereign obligations.
Banking entities may also hold foreign
sovereign debt in their long-term
investment book. In addition, the final
rule does not prevent foreign banking
entities from engaging in proprietary
1359 See Allen & Overy (Gov’t. Obligations);
HSBC.
1360 See Better Markets (Feb. 2012); Occupy; Prof.
Johnson; Sens. Merkley & Levin (Feb. 2012).
1361 See Prof. Johnson; Better Markets (Feb. 2012).
1362 See Better Markets (Feb. 2012); See also Prof.
Johnson.
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trading outside of the United States in
any type of sovereign debt.1363
Moreover, the Agencies continue to
believe that positions, including
positions in foreign government
obligations, acquired or taken for the
bona fide purpose of liquidity
management and in accordance with a
documented liquidity management plan
that is consistent with the relevant
Agency’s supervisory requirements,
guidance and expectations regarding
liquidity management are not covered
by the prohibitions in section 13.1364
The final rule continues to incorporate
this view.1365
The issue raised by commenters,
therefore, is the extent to which
proprietary trading in foreign sovereign
obligations by U.S. banking entities
anywhere in the world and by foreign
banking entities in the United States is
consistent with promoting and
protecting the safety and soundness of
the banking entity and the financial
stability of the United States. Taking
into account the information provided
by commenters, the Agencies’
understanding of market operations, and
the purpose and language of section 13,
the Agencies have determined to grant
a limited exemption to the prohibition
on proprietary trading for trading in
foreign sovereign obligations under
certain circumstances.
This exemption, which is contained
in § ll.6(b) of the final rule, permits
the U.S. operations of foreign banking
entities to engage in proprietary trading
in the United States in the foreign
sovereign debt of the foreign sovereign
under whose laws the banking entity—
or the banking entity that controls it—
is organized (hereinafter, the ‘‘home
country’’), and any multinational central
bank of which the foreign sovereign is
a member so long as the purchase or
sale as principal is not made by an
insured depository institution.1366
final rule § ll.6(e).
Joint Proposal, 76 FR 68,862.
1365 See final rule § ll.3(d)(3).
1366 See final rule § ll.6(b). Some commenters
requested an exemption for trading in obligations of
multinational central banks. See Ass’n. of German
Banks; Goldman (Prop. Trading); IIB/EBF; ICFR;
FIA; Mitsubishi; Sumitomo Trust; Allen & Overy
(Gov’t. Obligations). In the case of a foreign banking
entity that is owned or controlled by a second
foreign banking entity domiciled in a country other
than the home country of the first foreign banking
entity, the final rule would permit the eligible U.S.
operations of the first foreign banking entity to
engage in proprietary trading only in the sovereign
debt of the first foreign banking entity’s home
country, and would permit the U.S. operations of
the second foreign banking entity to engage in
proprietary trading only in the sovereign debt of the
home country of the second foreign banking entity.
As noted earlier, other provisions of the final rule
make clear that the rule does not restrict the
proprietary trading outside of the United States of
1363 See
1364 See
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Similar to the exemption for proprietary
trading in U.S. government obligations,
the permitted trading activity in the U.S.
by the eligible U.S. operations of a
foreign banking entity would extend to
obligations of political subdivisions of
the foreign banking entity’s home
country.1367
Permitting the eligible U.S. operations
of a foreign banking entity to engage in
proprietary trading in the United States
in the foreign sovereign obligations of
the foreign entity’s home country allows
these U.S. operations of foreign banking
entities to continue to support the
smooth functioning of markets in
foreign sovereign obligations in the
same manner as U.S. banking entities
are permitted to support the smooth
functioning of markets in U.S.
government and agency obligations.1368
At the same time, the risk of these
trading activities is largely determined
by the foreign sovereign that charters
the foreign bank. By not permitting
proprietary trading in foreign sovereign
debt in insured depository institutions
(other than in accordance with the
limitations in other exemptions), the
exemption limits the direct risks of
these activities to insured depository
institutions in keeping with the
statute.1369 Thus, the Agencies have
determined that this limited exemption
for proprietary trading in foreign
sovereign obligations promotes and
protects the safety and soundness of
banking entities and also promotes and
protects the financial stability of the
United States.
The Agencies have also determined to
permit a foreign bank or foreign brokereither foreign banking organization in debt of any
foreign sovereign.
1367 See Part IV.A.5.c., infra. Many commenters
requested an exemption for trading in foreign
sovereign debt, including obligations issued by
political subdivisions of foreign governments. See,
e.g., Allen & Overy (Gov’t. Obligations); BoA;
Australian Bankers Ass’n. (Feb. 2012); Banco de
´
Mexico; Bank of Canada; Ass’n. of German Banks;
BAROC; Barclays.
1368 As part of this exemption, for example, the
U.S. operations of a European bank would be able
to trade in obligations issued by the European
Central Bank. Many commenters represented that
the same rationale for exempting trading in U.S.
government obligations supports exempting trading
in foreign sovereign debt. See, e.g., Allen & Overy
´
(Gov’t. Obligations); Banco de Mexico; Barclays;
EFAMA; ICI (Feb. 2012).
1369 The Agencies believe this approach
appropriately balances commenter concerns that
proprietary trading in foreign sovereign obligations
represents a risky activity and the interest in
preserving the ability of U.S. operations of foreign
banking entities to continue to support the smooth
functioning of markets in foreign sovereign
obligations in the same manner as U.S. banking
entities are permitted to support the smooth
functioning of markets in U.S. government and
agency obligations. See Better Markets (Feb. 2012);
Occupy; Prof. Johnson; Sens. Merkley & Levin
(Feb. 2012).
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dealer regulated as a securities dealer
and controlled by a U.S. banking entity
to engage in proprietary trading in the
obligations of the foreign sovereign
under whose laws the foreign entity is
organized (hereinafter, the ‘‘home
country’’), including obligations of an
agency or political subdivision of that
foreign sovereign.1370 This limited
exemption is necessary to allow U.S.
banking organizations to continue to
own and acquire foreign banking
organizations and broker-dealers
without requiring those foreign banking
organizations and broker-dealers to
discontinue proprietary trading in the
sovereign debt of the foreign banking
entity’s home country.1371 The Agencies
have determined that this limited
exemption will promote the safety and
soundness of banking entities and the
financial stability of the United States
by allowing U.S. banking entities to
continue to be affiliated with and
operate foreign banking entities and
benefit from international
diversification and participation in
global financial markets.1372 However,
the Agencies intend to monitor activity
of banking entities under this exemption
to ensure that U.S. banking entities are
not seeking to evade the restrictions of
section 13 by using an affiliated foreign
bank or broker-dealer to engage in
proprietary trading in foreign sovereign
debt on behalf of or for the benefit of
other parts of the U.S. banking entity.
Apart from this limited exemption,
the Agencies have not extended this
exemption to proprietary trading in
foreign sovereign debt by U.S. banking
entities for several reasons. First, section
13 was primarily concerned with the
risks posed to the U.S. financial system
by proprietary trading activities. This
risk is most directly transmitted by U.S.
banking entities, and while commenters
alleged that prohibiting U.S. banking
entities from engaging in proprietary
final rule § ll.6(c). Many commenters
requested an exemption for trading in foreign
sovereign debt, and some commenters suggested
exempting proprietary trading by foreign banking
entities in obligations of their home country. See,
e.g., Allen & Overy (Gov’t. Obligations); BoA; FSA
(Apr. 2012); Cadwalader (on behalf of Thai Banks);
IIB/EBF; Ass’n. of Banks in Malaysia; UBS.
1371 Commenters argued that in some foreign
markets, U.S. banks operating in those jurisdictions
are required by local regulation or market practice
to trade in local sovereign securities. See, e.g., Allen
& Overy (Gov’t. Obligations); AFMA; Ass’n. of
German Banks; Barclays; EBF; Goldman (Prop.
Trading); UBS.
1372 Some commenters represented that the
limitations and obligations of section 13 would be
problematic and unduly burdensome on banking
entities because they would only be able to trade
in foreign sovereign obligations under existing
exemptions, such as the market-making exemption.
See Barclays; IIAC; UBS; Ass’n. of Banks in
Malaysia; IIB/EBF.
1370 See
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5643
trading in debt of foreign sovereigns
would harm liquidity in those markets,
the evidence provided by commenters
did not sufficiently indicate that
permitting U.S. banking entities to
engage in proprietary trading (as
opposed to market-making or
underwriting) in debt of foreign
sovereigns contributed in any
significant degree to the liquidity of
markets in foreign sovereign
instruments.1373 Thus, expanding the
exemption to permit U.S. banking
entities to engage in proprietary trading
in debt of foreign sovereigns would
likely increase the risks to these entities
and the U.S. financial system without a
significant concomitant and offsetting
benefit. As explained above, these U.S.
entities are permitted by the final rule
to continue to engage fully in marketmaking in and underwriting of debt of
foreign sovereigns anywhere in the
world. The only restriction placed on
these entities is on the otherwise
impermissible proprietary trading in
these instruments for the purpose of
selling in the near term or otherwise
with the intent to resell in order to
profit from short-term price movements.
The Agencies recognize that,
depending on the extent to which
banking entities subject to the rule have
contributed to the liquidity of trading
markets for foreign sovereign debt, the
lack of an exemption for proprietary
trading in foreign sovereign debt could
result in certain negative impacts on the
markets for such debt. In general, the
Agencies believe these concerns should
be mitigated somewhat by the refined
exemptions for market making,
underwriting and permitted trading
activity of foreign banking entities;
however, those exemptions do not
address certain of the collateral, capital,
and other operational issues identified
by commenters.1374 Foreign sovereign
1373 See, e.g., BoA; Citigroup; Goldman (Prop.
Trading); IIB/EBF; Allen & Overy (Gov’t.
Obligations); Australian Bankers Ass’n. (Feb. 2012).;
´
Banco de Mexico; Barclays. The Agencies recognize
some commenters’ representation that restricting
trading in foreign sovereign debt would not
necessarily cause reduced liquidity in government
bond markets because banking entities would still
be able to make a market in and underwrite foreign
government obligations. See Prof. Johnson; Better
Markets (Feb. 2012).
1374 Representatives from foreign governments
stated that an exemption allowing trading in
obligations of their governments is necessary to
maintain financial stability in their markets. See,
e.g., Allen & Overy (Gov’t. Obligations); Bank of
Canada; IRSG; IIB/EBF; Gov’t of Japan/Bank of
Japan; Australian Bankers Ass’n. (Feb. 2012); Banco
´
de Mexico; Ass’n. of German Banks; ALFI.
Commenters argued that exempting trading in
foreign sovereign debt would avoid the possible
negative impacts of a contraction of government
bond market liquidity. See, e.g., BoA; Citigroup;
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debt of home and host countries
generally serves these purposes. Due to
the relationships among global financial
markets, permitting trading that
supports these essential functions
promotes the financial stability and the
safety and soundness of banking
entities.1375 In contrast, a broad
exemption for proprietary trading in all
foreign sovereign debt without the
limitations contained in the
underwriting, market making and
hedging exemptions could lead to more
complicated risk profiles and significant
unhedged risk exposures that section 13
of the BHC Act is designed to address.
Thus, the Agencies believe use of
section 13(d)(1)(J) exemptive authority
to permit proprietary trading in foreign
government obligations in certain
limited circumstances is appropriate.
The Agencies decline to follow
commenters’ suggested alternative of
allowing trading in foreign government
obligations if the obligations meet a
particular condition on quality, such as
obligations of OECD member
countries.1376 The Agencies do not
believe such an approach responds to
the statutory purpose of limiting risks
posed to the U.S. financial system by
Goldman (Feb. 2012); IIB/EBF. Additionally,
commenters suggested that failing to provide an
exemption for this activity would impact money
market operations of foreign central banks and limit
the ability of foreign sovereign governments to
conduct monetary policy or finance their
operations. See, e.g., Barclays; BoA; Gov’t of Japan/
Bank of Japan; OSFI. A number of commenters also
argued that, since U.S. and foreign banking entities
often perform functions for foreign governments
similar to those provided in the U.S. by U.S.
primary dealers, the lack of an exemption would
have a significant, negative impact on the ability of
foreign governments to implement monetary policy
and on liquidity in many foreign markets. See, e.g.,
Allen & Overy (Gov’t. Obligations); Australian
´
Bankers Ass’n. (Feb. 2012); BoA; Banco de Mexico;
Barclays; Citigroup (Feb. 2012); Goldman (Prop.
Trading); IIB/EBF. Some commenters argued that
banking entities and their customers use foreign
sovereign debt to manage their risk by posting
collateral in foreign jurisdictions and to manage
international rate and foreign exchange risk. See
Citigroup (Feb. 2012); SIFMA et al. (Prop. Trading)
(Feb. 2012).
1375 The Agencies generally concur with
commenters’ concerns that because the lack of an
exemption could result in negative consequences—
such as harming liquidity in foreign sovereign debt
markets, making it more difficult and more costly
for foreign governments to fund themselves, or
subjecting banking entities to increased
concentration risk—systemic risk could increase or
there could be spillover effects that would harm
global markets, including U.S. markets. See IIF;
EBF; ICI Global; HSBC; Barclays; ICI (Feb. 2012);
IIB/EBF; Union Asset. Additionally, in
consideration of one commenter’s statements, the
Agencies believe that failing to provide this
exemption may cause foreign banks to close their
U.S. branches, which could harm U.S. markets. See
Comm. on Capital Markets Regulation.
1376 See, e.g., BoA; Cadwalader (on behalf of
Singapore Banks).; IIB/EBF; OSFI; UBS; BAROC;
Japanese Bankers Ass’n.; JPMC.
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proprietary trading activities as directly
as our current approach, which is
structured to limit the exposure of
banking entities, including insured
depository institutions, to the risks of
foreign sovereign debt. Additionally, the
Agencies decline to permit proprietary
trading in any obligation permitted
under the laws of the foreign banking
entity’s home country,1377 because such
an approach could result in unintended
competitive impacts since banking
entities would not be subject to one
uniform standard inside the United
States. Further, unlike some
commenters, the Agencies do not
believe it is appropriate to require
foreign governments to commit to
paying for any damage to the U.S.
financial system resulting from the
foreign sovereign debt exemption.1378
The proposal also did not contain an
exemption for trading in derivatives on
foreign government obligations. Many
commenters who recommended
providing an exemption for proprietary
trading in foreign government
obligations also requested that the
exemption be extended to derivatives on
foreign government obligations.1379 Two
of these commenters urged that trading
in derivatives on foreign sovereign
obligations should be exempt for the
same reason that trading in derivatives
on U.S. government obligations is
exempt because such trading supports
liquidity and price stability in the
market for the underlying government
obligations.1380 One commenter
recommended that the Agencies use the
authority in section 13(d)(1)(J) to grant
an exemption for proprietary trading in
derivatives on foreign government
obligations.1381
The final rule has not been modified
in § ll.6(b) to permit a banking entity
to engage in proprietary trading in
derivatives on foreign government
obligations. As noted above, the
Agencies have determined not to permit
proprietary trading in derivatives on
U.S. exempt government obligations
under section 13(d) and, for the same
reasons, have determined not to extend
the permitted activities to include
proprietary trading in derivatives on
foreign government obligations.
1377 Some commenters suggested permitting nonU.S. banking entities to trade in any government
obligation to the extent that such trading is
permitted by the entity’s primary regulator. See
Allen & Overy (Gov’t. Obligations); HSBC.
1378 See Better Markets (Feb. 2012); See also Prof.
Johnson.
1379 See Barclays; Credit Suisse (Seidel); IIB/EBF;
Japanese Bankers Ass’n.; Norinchukin; RBC;
Sumitomo Trust; UBS.
1380 See Barclays; FIA.
1381 See Barclays.
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c. Permitted Trading in Municipal
Securities
Section ll.6(a) of the proposed rule
implemented an exemption to the
prohibition against proprietary trading
under section 13(d)(1)(A) of the BHC
Act, which permits trading in certain
governmental obligations. This
exemption permits the purchase or sale
of obligations issued by any State or any
political subdivision thereof (the
‘‘municipal securities trading
exemption’’). The proposed rule
included both general obligation bonds
and limited obligation bonds, such as
revenue bonds, within the scope of this
municipal securities trading exemption.
The proposed rule, however, did not
extend to obligations of ‘‘agencies’’ of
States or political subdivisions
thereof.1382
Many commenters, including industry
participants, trade groups, and Federal
and state governmental representatives,
argued that the municipal securities
trading exemption should be interpreted
to permit banking entities to engage in
proprietary trading in a broader range of
municipal securities, including the
following: Obligations issued directly by
States and political subdivisions
thereof; obligations issued by agencies,
constituted authorities, and similar
governmental entities acting as
instrumentalities on behalf of States and
political subdivisions thereof; and
obligations issued by such governmental
entities that are treated as political
subdivisions under various more
expansive definitions of political
subdivisions under Federal and state
laws.1383 These commenters argued that
States and municipalities often issue
obligations through agencies and
instrumentalities and that these
obligations generally have the same
level of risk as direct obligations of
States and political subdivisions.1384
Commenters asserted that permitting
trading in a broader group of municipal
securities would be consistent with the
1382 See
Joint Proposal, 76 FR 68,878 n.165.
e.g., ABA (Keating); Ashurst; Ass’n. of
Institutional Investors (Feb. 2012); BoA; BDA (Feb.
2012); Capital Group; Chamber (Feb. 2012);
Citigroup (Jan. 2012); CHFA; Eaton Vance; Fidelity;
Fixed Income Forum/Credit Roundtable; HSBC;
MEFA; Nuveen Asset Mgmt.; Sens. Merkley & Levin
(Feb. 2012); Am. Pub. Power et al.; MSRB; Fidelity;
State of New York; STANY; SIFMA (Municipal
Securities) (Feb. 2012); State Street (Feb. 2012);
North Carolina; T. Rowe Price; Sumitomo Trust;
UBS; Washington State Treasurer; Wells Fargo
(Prop. Trading).
1384 See, e.g., CHFA; Sens. Merkley & Levin (Feb.
2012); Am. Pub. Power et al.; North Carolina;
Washington State Treasurer; See also NABL;
Ashurst; BDA (Feb. 2012); Chamber (Feb. 2012);
Eaton Vance; Fidelity; MEFA; MSRB; Am. Pub.
Power et al.; Nuveen Asset Mgmt.; PNC; SIFMA
(Municipal Securities) (Feb. 2012); UBS.
1383 See,
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terms and purposes of section 13 and
would not adversely affect the safety
and soundness of banking entities
involved in these transactions or create
additional risk to the financial stability
of the United States.1385
Commenters expressed concerns that
the proposed rule would result in a
bifurcation of the municipal securities
market that would achieve no
meaningful benefits to the safety and
soundness of banking entities, create
administrative burdens for determining
whether or not a municipal security
qualifies for the exemption, result in
inconsistent applications across
different States, increase costs, and
decrease liquidity in the diverse
municipal securities market.1386
Commenters also argued that the market
for securities issued by agencies and
instrumentalities of States and political
subdivisions thereof would be
especially disrupted, and would affect
about 40 percent of the municipal
securities market.1387
Commenters recommended that the
final rule provide a broad exemption to
the prohibition on proprietary trading
for municipal securities, based on the
definition of ‘‘municipal securities’’
used in section 3(a)(29) of the Exchange
Act,1388 which is understood by market
participants and by Congress, and has a
well-settled meaning and an established
body of law. 1389 Other commenters
contended that adopting the same
definition of municipal securities as
used in the Federal securities laws
would reduce regulatory burden,
remove uncertainty, and lead to
consistent treatment of these securities
under the banking and securities
laws.1390 According to some
commenters, the terms ‘‘agency’’ and
‘‘political subdivision’’ are used
differently under some State laws, and
some State laws identify certain
agencies as political subdivisions or
define political subdivision to include
agencies.1391 Commenters also noted
that a number of Federal statutes and
regulations define the term ‘‘political
subdivision’’ to include municipal
agencies and instrumentalities.1392
Commenters suggested that the
Agencies interpret the term ‘‘political
subdivision’’ in section 13 more broadly
than in the proposal to include a wider
range of State and municipal
governmental obligations issued by
agencies and instrumentalities or,
alternatively, that the Agencies use the
exemptive authority in section
13(d)(1)(J) if necessary to permit
proprietary trading of a broader array of
State and municipal obligations.1393
On the other hand, one commenter
contended that bonds issued by
agencies and instrumentalities of States
or municipalities pose risks to the
banking system because the commenter
1385 See Ashurst; Citigroup (Jan. 2012); Eaton
Vance; Am. Pub. Power et al.; SIFMA (Municipal
Securities) (Feb. 2012); North Carolina; T. Rowe
Price; Wells Fargo (Prop. Trading); See also Capital
Group (arguing that municipal securities are not
generally used as a profit making strategy and thus,
including all municipal securities in the exemption
by itself should not adversely affect the safety and
soundness of banking entities); PNC (arguing that
the safe and sound nature of trading in State and
municipal agency obligations was ‘‘a fact
recognized by Congress in 1999 when it authorized
well capitalized national banks to underwrite and
deal in, without limit, general obligation, limited
obligation and revenue bonds issued by or on behalf
of any State, or any public agency or authority of
any State or political subdivision of a State’’); Sens.
Merkley & Levin (Feb. 2012).
1386 See, e.g., MSRB; City of New York; Am. Pub.
Power et al.; Wells Fargo; State of New York;
Washington State Treasurer; ABA (Keating); Capital
Group; North Carolina; Eaton Vance; Port
Authority; Connecticut; Citigroup (Jan. 2012);
Ashurst; Nuveen Asset Mgmt.; SIFMA (Municipal
Securities) (Feb. 2012).
1387 See, e.g., MSRB (stating that, based on data
from Thomson Reuters, 41.4 percent of the
municipal securities issued in FY 2011 were issued
by agencies and authorities).
1388 See 15 U.S.C. 78c(a)(29).
1389 See ABA (Keating); Ashurst; BoA; Capital
Group; Chamber (Feb. 2012); Comm. on Capital
Markets Regulation; Citigroup (Jan. 2012); Eaton
Vance; Fidelity; MEFA; MTA–NY; MSRB; Am. Pub.
Power et al.; NABL; NCSL; State of New York;
Nuveen Asset Mgmt.; Port Authority; PNC; SIFMA
(Municipal Securities) (Feb. 2012); North Carolina;
T. Rowe Price; UBS; Washington State Treasurer;
Wells Fargo (Prop. Trading).
1390 See Ashurst; Citigroup (Jan. 2012) (noting
that the National Bank Act explicitly lists State
agencies and authorities as examples of political
subdivisions); MSRB.
1391 See, e.g., Citigroup (Jan. 2012).
1392 See, e.g., MSRB; Citigroup (Jan. 2012). In
addition to the Federal securities laws, the National
Bank Act explicitly includes agencies and
authorities as examples of political subdivisions.
See 12 U.S.C. 24(seventh) (permitting investments
in securities ‘‘issued by or on behalf of any State
or political subdivision of a State, including any
municipal corporate instrumentality of 1 or more
States, or any public agency or authority of any
State or political subdivision of a State . . . .’’). In
addition, a number of banking regulations also
include agencies as examples of political
subdivisions or define political subdivision to
include municipal agencies, authorities, districts,
municipal corporations and similar entities. See,
e.g., 12 CFR 1.2; 12 CFR 160.30; 12 CFR 161.38; 12
CFR 330.15. Further, for purposes of the tax-exempt
bond provisions in the Internal Revenue Code,
Treasury regulations treat obligations issued by or
‘‘on behalf of’’ States or political subdivisions by
‘‘constituted authorities’’ as obligations of such
States or political subdivisions, and the Treasury
regulations define the term ‘‘political subdivision’’
to mean ‘‘any division of any State or local
governmental unit which is a municipal
corporation or which has been delegated the right
to exercise part of the sovereign power of the
unit. . . .’’ See 26 CFR 1.103–1(b).
1393 See ABA (Keating); Ashurst; Ass’n. of
Institutional Investors (Feb. 2012); Citigroup (Jan.
2012); Comm. on Capital Markets Regulation; Sens.
Merkley & Levin (Feb. 2012); MSRB; Wells Fargo
(Prop. Trading); SIFMA et al. (Prop. Trading) (Feb.
2012).
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believed the market for these bonds has
not been properly regulated or
controlled.1394 A few commenters also
recommended tightening the proposed
municipal securities trading exemption
to exclude conduit obligations that
benefit private businesses and private
organizations.1395 One commenter
suggested that the proposed municipal
securities trading exemption should not
apply to tax-exempt municipal bonds
that benefit private businesses (referred
to as ‘‘private activity bonds’’ in the
Internal Revenue Code1396) and that
allow private businesses to finance
private projects at lower interest rates as
a result of the exemption from Federal
income taxation for the interest received
by investors.1397
The final rule includes the statutory
exemption for proprietary trading of
obligations of any State or political
subdivision thereof.1398 In response to
the public comments and for the reasons
discussed below, this exemption uses
the definition of the term ‘‘municipal
security’’ modeled after the definition of
‘‘municipal securities’’ under section
3(a)(29) of the Exchange Act,1399 but
1394 See
Occupy.
AFR et al. (Feb. 2012); Occupy.
1396 See 26 U.S.C. 141. In general, the rules
applicable to the issuance of tax-exempt private
activity bonds under the Internal Revenue Code of
1986, as amended (the ‘‘Code’’) are more restrictive
than those applicable to traditional governmental
bonds issued by States or political subdivisions
thereof. Section 146 of the Code imposes an annual
State bond volume cap on most tax-exempt private
activity bonds that is tied to measures of State
populations. Sections 141–150 of the Code impose
other additional restrictions on tax-exempt private
activity bonds, including, among others, eligible
project and use restrictions, bond maturity
restrictions, land and existing property financing
restrictions, an advance refunding prohibition, and
a public approval requirement.
1397 See AFR et al. (Feb. 2012).
1398 See final rule § __.6(a)(3).
1399 Many commenters requested that the final
rule use the definition of ‘‘municipal securities’’
used in the federal securities laws because, among
other reasons, the industry is familiar with that
definition and such an approach would promote
consistent treatment of these securities under
banking and securities laws. See, e.g., ABA
(Keating); Ashurst; BoA; Comm. on Capital Markets
Regulation; Citigroup (Jan. 2012); NCSL; Port
Authority; SIFMA (Municipal Securities) (Feb.
2012); MSRB. Section 3(a)(29) of the Exchange Act
defines the term ‘‘municipal securities’’ to mean
‘‘securities which are direct obligations of, or
obligations guaranteed as to principal or interest by,
a State or any political subdivision thereof, or any
agency or instrumentality of a State or any political
subdivision thereof, or any municipal corporate
instrumentality of one or more States, or any
security which is an industrial development bond
(as defined in section 103(c)(2) of Title 26) the
interest on which is excludable from gross income
under section 103(a)(1) of Title 26 if, by reason of
the application of paragraph (4) or (6) of section
103(c) of Title 26 (determined as if paragraphs
(4)(A), (5), and (7) were not included in such
section 103(c)), paragraph (1) of such section 103(c)
1395 See
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with simplifications.1400 The final rule
defines the term ‘‘municipal security’’ to
mean ‘‘a security which is a direct
obligation of or issued by, or an
obligation guaranteed as to principal or
interest by, a State or any political
subdivision thereof, or any agency or
instrumentality of a State or any
political subdivision thereof, or any
municipal corporate instrumentality of
one or more States or political
subdivisions thereof.’’
The final rule modifies the proposal
to permit proprietary trading in
obligations issued by agencies and
instrumentalities acting on behalf of
States and municipalities (e.g., port
authority bonds and bonds issued by
municipal agencies or corporations).1401
As noted by commenters, many States
and municipalities rely on securities
issued by agencies and instrumentalities
to fund essential activities, including
utility systems, infrastructure projects,
affordable housing, hospitals,
universities, and other nonprofit
institutions.1402 Both obligations issued
directly by States and political
subdivisions thereof and obligations
issued by an agency or instrumentality
of such a State or local governmental
entity are ultimately obligations of the
State or local governmental entity on
whose behalf they act. Moreover,
exempting obligations issued by State
does not apply to such security.’’ See 15 U.S.C.
78c(a)(29).
1400 The definition of municipal securities in
section 3(a)(29) of the Exchange Act has outdated
tax references to the prior law under the former
Internal Revenue Code of 1954, including
particularly references to certain provisions
involving the concept of ‘‘industrial development
bonds.’’ The successor current Internal Revenue
Code of 1986, as amended, replaces the prior
definition of ‘‘industrial development bonds’’ with
a revised, more restrictive successor definition of
‘‘private activity bonds’’ and related definitions of
‘‘exempt facility bonds’’ and ‘‘small issue bonds.’’
In recognition of the numerous tax law changes
since the last statutory revision of section 3(a)(29)
of the Exchange Act in 1970 and the potential
attendant confusion, the Agencies determined to
use a simpler, streamlined, independent definition
of municipal securities for purposes of the
municipal securities trading exception. This revised
definition is intended to encompass, among others,
any securities that are covered by the definition of
the term ‘‘municipal securities’’ under section
3(a)(29) of the Exchange Act.
1401 Many commenters requested that the
municipal securities trading exemption be
interpreted to include a broader range of State and
municipal obligations issued by agencies and
instrumentalities. See, e.g., ABA (Keating); Ashurst;
BoA; BDA (Feb. 2012); Fixed Income Forum/Credit
Roundtable; Sens. Merkley & Levin (Feb. 2012);
SIFMA (Municipal Securities) (Feb. 2012);
Citigroup (Jan. 2012); Comm. on Capital Markets
Regulation.
1402 See, e.g., Citigroup (Jan. 2012); Ashurst;
SIFMA et al. (Prop. Trading) (Feb. 2012); SIFMA
(Municipal Securities) (Feb. 2012); Chamber (Dec.
2011); BlackRock; Fixed Income Forum/Credit
Roundtable.
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and municipal agencies and
instrumentalities in the same manner as
the direct obligations of States and
municipalities lessens potential
inconsistent treatment of government
obligations across States and
municipalities that use different funding
methods for government projects.1403
The Agencies believe that interpreting
the language of section 13(d)(1)(A) of
the BHC Act to provide an exemption to
the prohibition on proprietary trading
for obligations issued by States and
municipal agencies and
instrumentalities as described above is
consistent with the terms and purposes
of section 13 of the BHC Act.1404 The
Agencies recognize that state and
political subdivision agency obligations
generally present the same level of risk
as direct obligations of States and
political subdivisions.1405 Moreover, the
Agencies recognize that other federal
laws and regulations define the term
‘‘political subdivision’’ to include
municipal agencies and
instrumentalities.1406 The Agencies
decline to exclude from this exemption
conduit obligations that benefit private
entities, as suggested by some
commenters.1407
1403 Commenters represented that the proposed
rule would result in inconsistent applications of the
exemption across States and political subdivisions.
The Agencies also recognize, as noted by
commenters, that the proposed rule would likely
have resulted in a bifurcation of the municipal
securities market and associated administrative
burdens and disruptions. See, e.g., MSRB; Am. Pub.
Power et al.; Port Authority; Citigroup (Jan. 2012);
SIFMA et al. (Prop. Trading) (Feb. 2012); SIFMA
(Municipal Securities) (Feb. 2012).
1404 Commenters asserted that permitting trading
in a broader group of municipal securities would
be consistent with the terms and purposes of
section 13. See, e.g., Ashurst; Citigroup (Jan. 2012);
Eaton Vance; Am. Pub. Power et al.; SIFMA
(Municipal Securities) (Feb. 2012).
1405 Commenters argued that obligations issued
by agencies and instrumentalities generally have
the same level of risk as direct obligations of States
and political subdivisions. See, e.g., CHFA; Sens.
Merkley & Levin (Feb. 2012); Am. Pub. Power et al.;
North Carolina. In response to one commenter’s
concern that the markets for bonds issued by
agencies and instrumentalities are not properly
regulated, the Agencies note that all types of
municipal securities, as defined under the
securities laws to include, among others, State
direct obligation bonds and agency or
instrumentality bonds, are generally subject to the
same regulations under the securities laws. Thus,
the Agencies do not believe that obligations of
agencies and instrumentalities are subject to less
effective regulation than obligations of States and
political subdivisions. See Occupy.
1406 Commenters noted that a number of federal
statutes and regulations define ‘‘political
subdivision’’ to include municipal agencies and
instrumentalities. See, e.g., MSRB; Citigroup (Jan.
2012).
1407 See AFR et al. (Feb. 2012); Occupy. The
Agencies do not believe it is appropriate to exclude
conduit obligations, which are tax-exempt
municipal bonds, from this exemption because such
obligations are used to finance important projects
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The proposal did not exempt
proprietary trading of derivatives on
obligations of States and political
subdivisions. The proposal solicited
comment on whether exempting
proprietary trading in options or other
derivatives referencing an obligation of
a State or political subdivision thereof
was consistent with the terms and
purpose of the statute.1408 The Agencies
did not receive persuasive information
on this topic and, for the same reasons
discussed above related to derivatives
on U.S. government securities, the
Agencies have determined not to
provide an exemption for proprietary
trading in municipal securities, beyond
the underwriting, market-making,
hedging and other exemptions provided
generally in the rule. The Agencies note
that banking entities may trade
derivatives on municipal securities
under any other available exemption to
the prohibition on proprietary trading,
providing the requirements of the
relevant exemption are met.
d. Determination to Not Exempt
Proprietary Trading in Multilateral
Development Bank Obligations
The proposal did not exempt
proprietary trading in obligations of
multilateral banks or derivatives on
multilateral development bank
obligations but requested comment on
this issue.1409 A number of commenters
argued that the final rule should include
an exemption for obligations of
multilateral development banks.1410
The Agencies have not included an
exemption to permit banking entities to
engage in proprietary trading in
obligations of multilateral development
banks at this time. The Agencies do not
believe that providing an exemption for
related to, for example, multi-family housing,
healthcare (hospitals and nursing homes), colleges
and universities, power and energy companies and
resource recovery facilities. See U.S. Securities &
Exchange Comm’n., Report on the Municipal
Securities Market 7 (2012), available at https://
www.sec.gov/news/studies/2012/
munireport073112.pdf.
1408 See Joint Proposal, 76 FR 68,878.
1409 See id.
1410 Commenters argued that including
obligations of multilateral developments banks in a
foreign sovereign debt exemption is necessary to
avoid endangering international cooperation in
financial regulation and potential retaliatory
prohibitions against U.S. government obligations.
See Ass’n. of German Banks; Sumitomo; SIFMA et
al. (Prop. Trading) (Feb. 2012). Additionally, some
commenters represented that an exemption for
obligations of international and multilateral
development banks is appropriate for many of the
same reasons provided for exempting U.S.
government obligations and foreign sovereign debt
generally. See Ass’n. of German Banks; Barclays;
Goldman (Prop. Trading); IIB/EBF; ICFR; ICI Global;
FIA; Sumitomo Trust; Allen & Overy (Gov’t.
Obligations); SIFMA et al. (Prop. Trading) (Feb.
2012).
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trading obligations of multilateral
development banks will help enhance
the markets for these obligations and
therefore promote and protect the safety
and soundness of banking entities and
U.S. financial stability.
6. Section ll.6(c): Permitted Trading
on Behalf of Customers
Section 13(d)(1)(D) of the BHC Act
provides an exemption from the
prohibition on proprietary trading for
the purchase, sale, acquisition, or
disposition of financial instruments on
behalf of customers.1411 The statute
does not define when a transaction or
activity is conducted ‘‘on behalf of
customers.’’
a. Proposed Exemption for Trading on
Behalf of Customers
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Section ll.6(b) of the proposed rule
implemented the exemption for trading
on behalf of customers by exempting
three types of trading activity. Section
ll.6(b)(i) of the proposed rule
provided that a purchase or sale of a
financial instrument occurred on behalf
of customers if the transaction (i) was
conducted by a banking entity acting as
investment adviser, commodity trading
advisor, trustee, or in a similar fiduciary
capacity for the account of that
customer, and (ii) involved solely
financial instruments for which the
banking entity’s customer, and not the
banking entity or any affiliate of the
banking entity, was the beneficial
owner. This exemption was intended to
permit trading activity that a banking
entity conducts in the context of
providing investment advisory, trust, or
fiduciary services to customers provided
that the banking entity structures the
activity so that the customer, and not
the banking entity, benefits from any
gains and suffers any losses on the
traded positions.
Section ll.6(b)(ii) of the proposed
rule exempted the purchase or sale of a
covered financial position if the banking
entity was acting as riskless
principal.1412 Under the proposed rule,
a banking entity qualified as a riskless
principal if the banking entity, after
having received an order to purchase or
sell a covered financial position from a
customer, purchased or sold the covered
financial position for its own account to
offset a contemporaneous sale to or
purchase from the customer.1413
U.S.C. 1851(d)(1)(D).
Joint Proposal, 76 FR 68,879.
1413 This language generally mirrors that used in
the Board’s Regulation Y, OCC interpretive letters,
and the SEC’s Rule 3a5–1 under the Exchange Act.
See 12 CFR 225.28(b)(7)(ii); 17 CFR 240.3a5–1(b);
OCC Interpretive Letter 626 (July 7, 1993).
Section ll.6(b)(iii) of the proposed
rule permitted trading by a banking
entity that was an insurance company
for the separate account of insurance
policyholders. Under the proposed rule,
only a banking entity that is an
insurance company directly engaged in
the business of insurance and subject to
regulation by a State insurance regulator
or foreign insurance regulator was
eligible for this prong of the exemption
for trading on behalf of customers.
Additionally, the purchase or sale of the
covered financial position was exempt
only if it was solely for a separate
account established by the insurance
company in connection with one or
more insurance policies issued by that
insurance company under which all
profits and losses arising from the
purchase or sale of the financial
instrument were allocated to the
separate account and inured to the
benefit or detriment of the owners of the
insurance policies supported by the
separate account, and not the banking
entity. These types of transactions are
customer-driven and do not expose the
banking entity to gains or losses on the
value of separate account assets even
though the banking entity is treated as
the owner of those assets for certain
purposes.
b. Comments on the Proposed Rule
Several commenters contended that
the Agencies construed the statutory
exemption too narrowly by limiting
permissible proprietary trading on
behalf of customers to only three
categories of transactions.1414 Some of
these commenters argued the exemption
in the proposal was not consistent with
the statutory language or Congressional
intent to permit all transactions that are
‘‘on behalf of customers.’’ 1415 One of
these commenters expressed concern
that the proposed exemption for trading
on behalf of customers may be
construed to permit only customerdriven transactions involving securities
and not other financial instruments
such as foreign exchange forwards and
other derivatives.1416
Several commenters urged the
Agencies to expand the exemption for
trading on behalf of customers to permit
other categories of customer-driven
transactions in which the banking entity
may be acting as principal but that serve
legitimate customer needs including
capital formation. For example, one
commenter urged the Agencies to
1411 12
1412 See
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1414 See, e.g., Am. Express; BoA; ISDA (Apr.
2012); RBC; SIMFA et al. (Prop. Trading) (Feb.
2012); Wells Fargo (Prop. Trading).
1415 See, e.g., Am. Express; SIMFA et al. (Prop.
Trading) (Feb. 2012).
1416 See Am. Express.
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5647
permit customer-driven transactions in
which the banking entity has no ready
counterparty but that are undertaken at
the instruction or request of a customer
or client or in anticipation of such an
instruction or request, such as
facilitating customer liquidity needs or
block positioning transactions.1417
Other commenters urged the Agencies
to exempt transactions where the
banking entity acts as principal to
accommodate a customer and
substantially and promptly hedges the
risks of the transaction.1418 Commenters
argued that these kinds of transactions
are similar in purpose and level of risk
to riskless principal transactions.1419
Commenters also argued that these
transactions could be viewed as marketmaking related activities, but indicated
that the potential uncertainty and costs
of making that determination would
discourage banking entities from taking
principal risks to accommodate
customer needs.1420 Commenters also
requested that the Agencies expressly
permit transactions on behalf of
customers to create structured products,
as well as for client funding needs,
customer clearing, and prime brokerage,
if these transactions are included within
the trading account.1421
In contrast, some commenters
supported the proposed approach for
implementing the exemption for trading
on behalf of customers or urged
narrowing the exemption.1422 One
commenter expressed general support
for the requirement that all profits (or
losses) from the transaction flow to the
customer and not the banking entity
providing the service for a transaction to
be exempt.1423 One commenter
contended that the statute did not
permit transactions on behalf of
customers to be performed by an
investment adviser.1424 Another
commenter argued that the final rule
should permit a banking entity to
engage in a riskless principal
transaction only where the banking
entity has already arranged for another
customer to be on the other side of the
transaction.1425 Other commenters
urged the Agencies to ensure that both
parties to the transaction agree
1417 See RBC. The Agencies note that acting as a
block positioner is expressly contemplated and
included as part of the exemption for market
making-related activities under the final rule.
1418 See BoA; SIMFA et al. (Prop. Trading) (Feb.
2012).
1419 See SIMFA et al. (Prop. Trading) (Feb. 2012).
1420 See SIMFA et al. (Prop. Trading) (Feb. 2012).
1421 See SIMFA et al. (Prop. Trading) (Feb. 2012).
1422 See, e.g., Alfred Brock; ICBA; Occupy.
1423 See ICBA.
1424 See Occupy.
1425 See Public Citizen.
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beforehand to the time and price of any
relevant trade to ensure that the banking
entity solely stands in the middle of the
transaction and in fact passes on all
gains (or losses) from the transaction to
the customers.1426 Commenters also
urged the Agencies to define other key
terms used in the exemption. For
instance, some commenters requested
that the final rule define which entities
may qualify as a ‘‘customer’’ for
purposes of the exemption.1427
Some commenters urged the Agencies
to provide uniform guidance on how the
Agencies will interpret the riskless
principal exemption.1428 One
commenter urged the Agencies to clarify
how the riskless principal exemption
would be implemented with respect to
transactions in derivatives, including a
hedged derivative transaction executed
at the request of a customer.1429
Several commenters generally
expressed support for the exemption for
trading for the separate account of
insurance policyholders under the
proposed rule.1430 One commenter
requested that the final rule more
clearly articulate who may qualify as a
permissible owner of an insurance
policy to whom the profits and losses
arising from the purchase or sale of a
financial instrument allocated to the
separate account may inure.1431
Several commenters argued that
certain types of separate account
activities, including the allocation of
seed money by an insurance company to
a separate account or the offering of
certain non-variable separate account
contracts by the insurance company,
would not appear to be permitted under
the proposal.1432 Commenters also
expressed concern that these separate
account activities might not satisfy the
proposed requirement that all profits
and losses arising from the purchase or
sale of the financial position inure to the
benefit or detriment of the owners of the
insurance policies supported by the
separate account, and not the insurance
company.1433 In addition, commenters
argued that under the proposed rule,
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1426 See
Occupy; Alfred Brock.
1427 See Occupy; Public Citizen. Conversely, other
commenters supported the approach taken in the
proposed rule without requesting such a definition.
See Alfred Brock.
1428 See, e.g., Am. Express; SIMFA et al. (Prop.
Trading) (Feb. 2012).
1429 See Am. Express.
1430 See ACLI; Chris Barnard; NAMIC; Fin.
Services Roundtable (Feb. 3, 2012).
1431 See Chris Barnard.
1432 See ACLI; Sutherland (on behalf of Comm. of
Annuity Insurers); Fin. Services Roundtable (Feb. 3,
2012); NAMIC.
1433 See ACLI; Sutherland (on behalf of Comm. of
Annuity Insurers); Fin. Services Roundtable (Feb. 3,
2012); NAMIC.
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these activities would appear to fall
outside of the exemption for activities in
the general account of an insurance
company because the proposed rule
defined a general account as excluding
a separate account.1434 Commenters
urged the Agencies to more closely align
the exemptions for trading by an
insurance company for the general
account and separate account.1435
According to these commenters, this
change would permit insurance
companies to continue to engage in the
business of insurance by offering the
full suite of insurance products to their
customers.1436
c. Final Exemption for Trading on
Behalf of Customers
The Agencies have carefully
considered the comments and are
adopting the exemption for trading on
behalf of customers with several
modifications. The Agencies believe
that the final rule implements the
exemption in section 13(d)(1)(D) in a
manner consistent with the legislative
intent to allow banking entities to use
their own funds to purchase or sell
financial instruments when acting on
behalf of their customers.1437 At the
same time, the limited activities
permitted under the final rule limit the
potential for abuse.1438
The final rule slightly modifies the
proposed rule by providing that a
banking entity is not prohibited from
trading on behalf of customers when
that activity is conducted by the
banking entity as trustee or in a similar
fiduciary capacity for a customer and so
long as the transaction is conducted for
the account of, or on behalf of the
customer and the banking entity does
not have or retain a beneficial
ownership of the financial instruments.
The final rule removes the proposal’s
express exemption for investment
advisers. After further consideration, the
Agencies do not believe an express
reference to investment advisers is
necessary because investment advisers
1434 See ACLI; Sutherland (on behalf of Comm. of
Annuity Insurers); Fin. Services Roundtable (Feb. 3,
2012); NAMIC.
1435 See ACLI; Sutherland (on behalf of Comm. of
Annuity Insurers); Fin. Services Roundtable (Feb. 3,
2012); NAMIC.
1436 See ACLI; Sutherland (on behalf of Comm. of
Annuity Insurers); Fin. Services Roundtable (Feb. 3,
2012); NAMIC.
1437 See 156 Cong. Rec. S5896 (daily ed. July 15,
2010) (statement of Sen. Merkley) (arguing that
‘‘this permitted activity is intended to allow
financial firms to use firm funds to purchase assets
on behalf of their clients, rather than on behalf of
themselves.’’).
1438 Some commenters urged narrowing the
exemption. See, e.g., Alfred Brock; ICBA; Occupy.
The Agencies believe the final rule is appropriately
narrow to limit potential abuse.
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generally act in a fiduciary capacity on
behalf of clients in a manner that is
separately covered by other exclusions
and exemptions in the final rule.
Additionally, the final rule deletes the
proposal’s express exemption for
commodity trading advisors because the
legal relationship between a commodity
trading advisor and its client depends
on the facts and circumstances of each
relationship. Therefore, the Agencies
determined that it was appropriate to
limit the discussion to fiduciary
obligations generally and to omit any
specific discussion of commodity
trading advisors. In order to ensure that
a banking entity utilizes this exemption
to engage only in transactions for
customers and not to conduct its own
trading activity, the final rule
(consistent with the proposed rule)
requires that the purchase or sale of
financial instruments be conducted for
the account of the customer and that it
involve solely financial instruments of
which the customer, and not the
banking entity, is beneficial owner.1439
The final rule, like the proposed rule,
permits transactions in any financial
instrument, including derivatives such
as foreign exchange forwards, so long as
those transactions are on behalf of
customers.1440
While some commenters requested
that the final rule define ‘‘customer’’ for
purposes of this exemption,1441 the
Agencies believe the requirements of
this exemption address commenters’
underlying concerns about what
constitutes a ‘‘customer.’’ Specifically,
the Agencies believe that requiring a
transaction relying on this exemption to
be conducted in a fiduciary capacity for
a customer, to be conducted for the
account of the customer, and to involve
solely financial instruments of which
the customer is beneficial owner
address the underlying concerns that a
transaction could qualify for this
exemption if done on behalf of an
indirect customer or on behalf of a
customer not served by the banking
entity.
The final rule also provides that a
banking entity may act as riskless
principal in a transaction in which the
banking entity, after receiving an order
to purchase (or sell) a financial
instrument from a customer, purchases
(or sells) the financial instrument for its
1439 See final rule § ll.6(c)(1)(ii)–(iii). See also
proposed rule § ll.6(b)(2)(i)(B)–(C).
1440 Some commenters expressed concern that the
proposed exemption for trading on behalf of
customers may be construed to not permit
transactions in foreign exchange forwards and other
derivatives. See Am. Express; SIFMA et al. (Prop.
Trading) (Feb. 2012).
1441 See Occupy; Public Citizen.
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own account to offset the
contemporaneous sale of the financial
instrument to (purchase from) the
customer.1442 Any transaction
conducted pursuant to the exemption
for riskless principal activity must be
customer-driven and may not expose
the banking entity to gains (or losses) on
the value of the traded instruments as
principal.1443 Importantly, the final rule
does not permit a banking entity to
purchase (or sell) a financial instrument
without first having a customer order to
buy (sell) the instrument. While some
commenters requested that the Agencies
modify the final rule to permit activity
without a customer order,1444 the
Agencies are concerned that broadening
the exemption in this manner would
enable banking entities to evade the
requirements of section 13 and engage
in prohibited proprietary trading under
the guise of trading on behalf of
customers.
Several commenters requested that
the final rule explain how a banking
entity may determine when it is acting
as riskless principal.1445 The Agencies
note that riskless principal transactions
typically are undertaken as an
alternative method of executing orders
by customers to buy or sell financial
instruments on an agency basis. Acting
as riskless principal does not include
acting as underwriter or market maker
in the particular financial instrument
and is generally understood to be
equivalent to agency or brokerage
transactions in which all of the risks
associated with ownership of financial
instruments are borne by customers.
The Agencies have generally equivalent
standards for determining when a
banking entity acts as riskless principal
and require that the banking entity, after
receiving an order to buy (or sell) a
financial instrument from a customer,
buys (or sells) the instrument for its own
account to offset a contemporaneous
sale to (or purchase from) the
customer.1446 The Agencies intend to
determine whether a banking entity acts
final rule § ll.6(c)(2).
commenters urged the Agencies to
ensure that the banking entity passes on all gains
(or losses) from the transaction to the customers.
See Occupy; Public Citizen.
1444 See RBC; SIFMA et al. (Prop. Trading) (Feb.
2012).
1445 See, e.g., Am. Express; SIFMA et al. (Prop.
Trading) (Feb. 2012).
1446 See, e.g., 12 CFR 225.28(b)(7)(ii); 17 CFR
240.3a5–1(b); OCC Interpretive Letter 626 (July 7,
1993). One commenter stated that a banking entity
should only be allowed to engage in a riskless
principal transaction where the banking entity has
already arranged for another customer to be on the
other side of the transaction. See Public Citizen.
The Agencies believe that the contemporaneous
requirement in the final rule addresses this
comment.
1442 See
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as riskless principal in accordance with
and subject to the requirements of these
standards.
Some commenters requested that the
final rule permit a greater variety of
transactions to be conducted on behalf
of customers. Many of these
transactions, such as transactions that
facilitate customer liquidity needs or
block positioning transactions 1447 or
transactions in which the banking entity
acts as principal to accommodate a
customer and substantially and
promptly hedges the risks of the
transaction,1448 may be permissible
under the market-making exemption. To
the extent these transactions are
conducted by a market maker, the
Agencies believe that the restrictions
and limits required in connection with
market making-related activities are
important for limiting the risks to the
banking entity from these
transactions.1449 While some
commenters requested that clearing and
settlement activities and prime
brokerage activities be viewed as
permitted proprietary trading on behalf
of customers,1450 these transactions are
not considered proprietary trading as an
initial matter under the final rule.1451
Finally, the Agencies have decided to
move the exemption for trading activity
conducted by an insurance company for
a separate account into the provision
exempting trading activity in an
insurance company’s general account in
order to better align the two
exemptions.1452 As discussed below in
Part IV.A.7., the final rule provides
exemptions for trading activity
1447 One commenter requested an exemption for
transactions at the instruction or request of a
customer or client or in anticipation of such an
instruction or request, such as facilitating customer
liquidity needs or block positioning transactions.
See RBC.
1448 Some commenters requested an exemption
for these types of transactions. See BoA; SIFMA et
al. (Prop. Trading) (Feb. 2012).
1449 Some commenters stated that the potential
uncertainty and costs of determining whether an
activity qualifies for the market-making exemption
would discourage banking entities from taking
principal risks to accommodate customer needs.
See, e.g., SIFMA et al. (Prop. Trading) (Feb. 2012).
The Agencies believe that adjustments made to the
market-making exemption in the final rule help
address this concern. Specifically, the final marketmaking exemption better accounts for the varying
characteristics of market-making across markets and
assets classes.
1450 See, e.g., SIFMA et al. (Prop. Trading) (Feb.
2012).
1451 See final rule § ll.3(d)(4)–(6). See also infra
Part IV.A.1.d.3–4.
1452 Some commenters requested that the
Agencies more closely align the exemptions for
trading by an insurance company for the general
account and separate account. See ACLI;
Sutherland (on behalf of Comm. of Annuity
Insurers); Fin. Services Roundtable (Feb. 3, 2012);
NAMIC.
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5649
conducted by an insurance company
that is a banking entity either in the
general account or in a separate account
of customers in § ll.6(d). As
explained below, the statute specifically
exempts trading activity that is
conducted by a regulated insurance
company engaged in the business of
insurance for the general account of the
company if conducted in accordance
with applicable state law and if not
prohibited by the appropriate Federal
banking agencies.1453 Unlike activity for
the general account of an insurance
company, investments made by
regulated insurance companies in
separate accounts in accordance with
applicable state law are made on behalf
of and for the benefit of customers of the
insurance company.1454 Also unlike
general accounts (which are supported
by all of the assets of the insurance
company), a separate account is
supported only by the assets in that
account and does not have call on the
other assets of the company. The
customer benefits (or loses) based solely
on the performance of the assets in the
separate account. These arrangements
are the equivalent for insurance
companies of fiduciary accounts at
banks. For these reasons, the final rule
recognizes that separate accounts at
regulated insurance companies
maintained in accordance with
applicable state insurance laws are
exempt from the prohibitions in section
13 as acquisitions on behalf of
customers.
7. Section ll.6(d): Permitted Trading
by a Regulated Insurance Company
Section 13(d)(1)(F) permits a banking
entity that is a regulated insurance
company acting for its general account,
1453 See
12 U.S.C. 1851(d)(1)(F).
commenter requested clarification on
who may qualify as a permissible owner of an
insurance policy to whom the profits and losses
arising from the purchase or sale of a financial
instrument allocated to the separate account may
inure. See Chris Barnard. The Agencies note that
the proposed requirement that all profits and losses
arising from the purchase or sale of a financial
instrument inure to the benefit or detriment of the
‘‘owners of the insurance policies supported by the
separate account’’ has been removed. See proposed
rule § ll.6(b)(2)(iii)(C). Instead, the final rule
requires that the income, gains, and losses from
assets allocated to a separate account be credited to
or charged against the account without regard to
other income, gains or losses of the insurance
company. See final rule § ll.2(z) (definition of
‘‘separate account’’). Thus, the final rule no longer
references ‘‘owners of the insurance policies
supported by the separate account.’’ The Agencies
note, however, that the final rule requires exempted
separate account transactions to be ‘‘conducted in
compliance with, and subject to, the insurance
company investment laws, regulations, and written
guidance of the State or jurisdiction in which such
insurance company is domiciled.’’ See final rule
§ ll.6(d)(3).
1454 One
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or an affiliate of an insurance company
acting for the insurance company’s
general account, to purchase or sell a
financial instrument subject to certain
conditions (the ‘‘general account
exemption’’).1455 Section 13(d)(1)(D)
permits a banking entity to purchase or
sell a financial instrument on behalf of
customers.1456 In the proposed rule, the
Agencies viewed Section 13(d)(1)(D) as
permitting an insurance company to
purchase or sell a financial instrument
for certain separate accounts (the
‘‘separate account exemption’’). The
proposal implemented both these
exemptions with respect to activities of
insurance companies, in each case
subject to the restrictions discussed
below.1457
Section ll.6(c) of the proposed rule
implemented the general account
exemption by generally restating the
statutory requirements of the exemption
that:
• The insurance company directly
engage in the business of insurance and
be subject to regulation by a State
insurance regulator or foreign insurance
regulator;
• The insurance company or its
affiliate purchase or sell the financial
instrument solely for the general
account of the insurance company;
• The purchase or sale be conducted
in compliance with, and subject to, the
insurance company investment laws,
regulations, and written guidance of the
State or jurisdiction in which such
insurance company is domiciled; and
• The appropriate Federal banking
agencies, after consultation with the
Council and the relevant insurance
commissioners of the States, must not
have jointly determined, after notice
and comment, that a particular law,
regulation, or written guidance
described above is insufficient to protect
the safety and soundness of the banking
entity or of the financial stability of the
United States.
The proposed rule defined the term
‘‘general account’’ to include all of the
assets of the insurance company that are
not legally segregated and allocated to
separate accounts under applicable
State law.1458
As noted above in Part IV.A.6.a.,
§ ll.6(b)(iii) of the proposed rule
provided an exemption for a banking
entity that is an insurance company
when it acted through a separate
account for the benefit of insurance
policyholders. The proposed rule
1455 See
12 U.S.C. 1851(d)(1)(F).
12 U.S.C. 1851(d)(1)(D).
1457 See proposed rule §§ ll.6(b)(2)(iii), ll
.6(c).
1458 See proposed rule § ll.3(c)(6).
1456 See
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defined a ‘‘separate account’’ as an
account established or maintained by a
regulated insurance company subject to
regulation by a State insurance regulator
or foreign insurance regulator under
which income, gains, and losses,
whether or not realized, from assets
allocated to such account, are, in
accordance with the applicable contract,
credited to or charged against such
account without regard to other income,
gains, or losses of the insurance
company.1459
To limit the potential for abuse of the
separate account exemption, the
proposed rule included requirements
designed to ensure that the separate
account trading activity is subject to
appropriate regulation and supervision
under insurance laws and not structured
so as to allow gains or losses from
trading activity to inure to the benefit or
detriment of the banking entity.1460 In
particular, the proposed rule provided
that a purchase or sale of a financial
instrument qualified for the separate
account exemption only if:
• The banking entity is an insurance
company directly engaged in the
business of insurance and subject to
regulation by a State insurance regulator
or foreign insurance regulator; 1461
• The banking entity purchases or
sells the financial instrument solely for
a separate account established by the
insurance company in connection with
one or more insurance policies issued
by that insurance company;
• All profits and losses arising from
the purchase or sale of the financial
instrument are allocated to the separate
account and inure to the benefit or
detriment of the owners of the insurance
policies supported by the separate
account, and not the banking entity; and
• The purchase or sale is conducted
in compliance with, and subject to, the
insurance company investment and
other laws, regulations, and written
guidance of the State or jurisdiction in
which such insurance company is
domiciled.
The proposal explained that the
proposed separate account exception
represented transactions on behalf of
customers because the insurance-related
transactions are generally customerdriven and do not expose the banking
entity to gains or losses on the value of
proposed rule § ll.2(z).
Agencies noted in the proposal they
would not consider profits to inure to the benefit
of the banking entity if the banking entity were
solely to receive payment, out of separate account
profits, of fees unrelated to the investment
performance of the separate account.
1461 The proposed rule provided definitions of the
terms ‘‘State insurance regulator’’ and ‘‘foreign
insurance regulator.’’ See proposed rule §§ ll
.3(c)(4), (13).
1459 See
1460 The
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separate account assets, even though the
banking entity may be treated as the
owner of those assets for certain
purposes.
Commenters generally supported the
general account exemption and the
separate account exemption for
regulated insurance companies as
consistent with both the statute and
Congressional intent to accommodate
the business of insurance.1462 For
instance, commenters argued that the
statute was designed to appropriately
accommodate the business of insurance,
subject to regulation in accordance with
relevant insurance company investment
laws, in recognition that insurance
company investment activities are
already subject to comprehensive
regulation and oversight.1463
A few commenters expressed
concerns about the definition of
‘‘general account’’ and ‘‘separate
account.’’ 1464 One commenter argued
the definition of general account was
unclear.1465 A few commenters
expressed concern that the proposed
definition of separate account
inappropriately excluded some separate
accounts, such as certain insurance
company investment activities such as
guaranteed investment contracts, which
would also not fall within the proposed
definition of general account.1466
Several commenters argued that the
final rule should be modified so that all
insurance company investment activity
permitted under applicable insurance
laws would qualify for either the general
account exemption or the separate
account exemption.1467
Some commenters argued that the
prohibition in the proposed definition
of separate account against any profits
or losses from activity in the account
inuring to the benefit (or detriment) of
the insurance company would exclude
some activity permitted by insurance
regulation in separate accounts.1468 For
example, commenters contended that an
insurer may allocate its own funds to a
separate account as ‘‘seed money’’ and
1462 See, e.g., Alfred Brock; Chris Barnard; Fin.
Services Roundtable (Feb. 3, 2012); Sutherland (on
behalf of Comm. of Annuity Insurers); TIAA–CREF;
NAMIC.
1463 See, e.g., ACLI (Jan. 2012); Fin. Services
Roundtable (Feb. 3, 2012); Country Fin. et al.;
Sutherland (on behalf of Comm. of Annuity
Insurers).
1464 See, e.g., Fin. Services Roundtable (Feb. 3,
2012); ACLI (Jan. 2012); Sutherland (on behalf of
Comm. of Annuity Insurers).
1465 See Sutherland (on behalf of Comm. of
Annuity Insurers).
1466 See ACLI (Jan. 2012); NAMIC.
1467 See Fin. Services Roundtable (Feb. 3, 2012);
ACLI (Jan. 2012); NAMIC; See also Nationwide.
1468 See Fin. Services Roundtable (Feb. 3, 2012);
ACLI (Jan. 2012); NAMIC; Sutherland (on behalf of
Comm. of Annuity Insurers); See also Nationwide.
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the profits and losses on those funds
inure to the benefit or detriment of the
insurance company.1469
Some commenters expressed specific
concerns about the scope or
requirements of the proposal. For
instance, one commenter argued that the
final rule should provide that a trade is
exempt if the trade is made by an
affiliate of the insurance company in
accordance with state insurance law.1470
Another commenter urged that the
Agencies consult with the foreign
insurance supervisor of an insurance
company regulated outside of the
United States before finding that an
insurance activity conducted by the
foreign insurance company was
inconsistent with the safety and
soundness or financial stability.1471
One commenter suggested that
insurance company affiliates of banking
entities should expressly be made
subject to data collection and reporting
requirements to prevent possible
evasion of the restrictions of section 13
and the final rule using their insurance
affiliates.1472 By contrast, other
commenters argued that the reporting
and recordkeeping and compliance
requirements of the rule should not
apply to permitted insurance company
investment activities.1473 These
commenters argued that insurance
companies are already subject to
comprehensive regulation of the kinds
and amounts of investments they can
make under insurance laws and
regulations and that additional
recordkeeping obligations would
impose unnecessary compliance
burdens on these entities without
producing significant offsetting benefits.
After considering the comments
received and the language and purpose
of the statute, the final rule has been
modified to better account for the
language of the statute and more
appropriately accommodate the
business of insurance.
As explained in the proposal, section
13(d)(1)(F) of the BHC Act specifically
and broadly exempts the purchase, sale,
acquisition, or disposition of securities
and other instruments by a regulated
insurance company engaged in the
business of insurance for the general
account of the company (and by an
affiliate solely for the general account of
the regulated insurance company).
Section 13(d)(1)(D) of the statute also
1469 See
Fin. Services Roundtable (Feb. 3, 2012);
ACLI (Jan. 2012).
1470 See USAA.
1471 See HSBC Life.
1472 See Sens. Merkley & Levin (Feb. 2012).
1473 See ACLI (Jan. 2012); Fin. Services
Roundtable (Feb. 3, 2012); Mutual of Omaha;
NAMIC.
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specifically exempts the same activity
when done on behalf of customers. As
explained in the proposal, separate
accounts managed and maintained by
insurance companies as part of the
business of insurance are generally
customer-driven and do not expose the
banking entity to gains or losses on the
value of assets held in the separate
account, even though the banking entity
may be treated as the owner of the assets
for certain purposes. Unlike the general
account of the insurance company,
separate accounts are managed on
behalf of specific customers, much as a
bank would manage a trust or fiduciary
account.
For these reasons, the final rule
retains both the general account
exemption and the separate account
exemption. The final rule removes any
gap between the definition of general
account and the definition of separate
account by defining the general account
to be all of the assets of an insurance
company except those allocated to one
or more separate accounts.1474
The final rule also combines the
general account exemption and the
separate account exemption into a
single section. This makes clear that
both exemptions are available only:
• If the insurance company or its
affiliate purchases or sells the financial
instruments solely for the general
account of the insurance company or a
separate account of the insurance
company;
• The purchases or sales of financial
instruments are conducted in
compliance with, and subject to, the
insurance company investment laws,
regulations, and written guidance of the
State or jurisdiction in which such
insurance company is domiciled; and
• The appropriate Federal banking
agencies, after consultation with the
Financial Stability Oversight Council
and the relevant insurance
commissioners of the States and
relevant foreign jurisdictions, as
appropriate, have not jointly
determined, after notice and comment,
that a particular law, regulation, or
written guidance regarding insurance is
insufficient to protect the safety and
soundness of the banking entity, or the
1474 See final rule §§ ll.2(p), (bb). Some
commenters expressed concerns about the proposed
definitions of ‘‘general account’’ and ‘‘separate
account,’’ including that the proposed definition of
‘‘separate account’’ excluded some legitimate
separate account activities that do not fall within
the proposed general account definition. See, e.g.,
ACLI (Jan. 2012); NAMIC; Sutherland (on behalf of
Comm. of Annuity Insurers). See also proposed rule
§§ ll.2(z), ll.3(c)(5).
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5651
financial stability of the United
States.1475
Like section 13(d)(1)(F) of the BHC
Act, the final rule permits an affiliate of
an insurance company to purchase and
sell financial instruments in reliance on
the general account exemption, so long
as that activity is for the general account
of the insurance company. Similarly,
the final rule implements section
13(d)(1)(D) and permits an affiliate of an
insurance company to purchase and sell
financial instruments for a separate
account of the insurance company, so
long as the separate account is
established and maintained at the
insurance company.
Importantly, the final rule applies
only to covered trading activity in a
general or separate account of a licensed
insurance company engaged in the
business of insurance under the
supervision of a State or foreign
insurance regulator. As in the statute, an
affiliate of an insurance company may
not rely on this exemption for activity
in any account of the affiliate (unless it,
too, meets the definition of an insurance
company). An affiliate may rely on the
exemption to the limited extent that the
affiliate is acting solely for the account
of the insurance company.1476
As noted above, one commenter
requested that the final rule impose
special data and reporting obligations
on insurance companies. Other
commenters argued that insurance
companies are already subject to
comprehensive regulation under
insurance laws and regulations and that
additional recordkeeping obligations
would impose unnecessary compliance
burdens on these entities without
producing significant offsetting benefits.
1475 The Federal banking agencies have not at this
time determined, as part of the final rule, that the
insurance company investment laws, regulations,
and written guidance of any particular State or
jurisdiction are insufficient to protect the safety and
soundness of the banking entity, or of the financial
stability of the United States. The Federal banking
agencies expect to monitor, in conjunction with the
FSOC, the insurance company investment laws,
regulations, and written guidance of States or
jurisdictions to which exempt transactions are
subject and make such determinations in the future,
where appropriate. The Agencies believe the final
approach addresses one commenter’s request that
the Agencies consult with the foreign insurance
supervisor of an insurance company regulated
outside of the United States before finding that an
insurance activity conducted by the foreign
company was inconsistent with the safety and
soundness or financial stability. See HSBC Life.
1476 Although one commenter requested that the
final rule exempt a trade as long as the trade is
made by an affiliate of the insurance company in
accordance with state insurance law, the Agencies
believe the final approach properly implements the
statute. See USAA.
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In accordance with the statute,1477 the
Agencies expect insurance companies to
have appropriate compliance programs
in place for any activity subject to
section 13 of the BHC Act.
The final rule contains a number of
other related definitions that are
intended to help make clear the
limitations of the insurance company
exemption, including definitions of
foreign insurance regulator and State
insurance regulator.
8. Section ll.6(e): Permitted Trading
Activities of a Foreign Banking Entity
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Section 13(d)(1)(H) of the BHC
Act 1478 permits certain foreign banking
entities to engage in proprietary trading
that occurs solely outside of the United
States (the ‘‘foreign trading
exemption’’).1479 The statute does not
define when a foreign banking entity’s
trading occurs solely outside of the
United States.
The proposed rule defined both the
type of foreign banking entity that is
eligible for the exemption and activity
that constitutes trading solely outside of
the United States. The proposed rule
effectively precluded a foreign banking
entity from engaging in proprietary
trading through a transaction that had
any connection with the United States,
including: Trading with any party
located in the United States; allowing
U.S. personnel of the foreign banking
entity to be involved in the purchase or
sale; or executing any transaction in the
United States (on an exchange or
otherwise).1480
In general, commenters emphasized
the importance of and supported an
exemption for foreign trading activities
of foreign banking entities. However, a
number of commenters expressed
concerns that the proposed foreign
trading exemption was too narrow and
would not be effective in permitting
foreign banking entities to engage in
1477 See 12 U.S.C. 1851(e)(1) (requiring that the
Agencies issue regulations regarding ‘‘internal
controls and recordkeeping, in order to insure
compliance with this section’’).
1478 Section 13(d)(1)(H) of the BHC Act provides
an exemption to the prohibition on proprietary
trading for trading conducted by a foreign banking
entity pursuant to paragraph (9) or (13) of section
4(c) of the BHC Act, if the trading occurs solely
outside of the United States, and the banking entity
is not directly or indirectly controlled by a banking
entity that is organized under the laws of the United
States or of one or more States. See 12 U.S.C.
1851(d)(1)(H).
1479 This section’s discussion of the concept
‘‘solely outside of the United States’’ is provided
solely for purposes of the rule’s implementation of
section 13(d)(1)(H) of the BHC Act, and does not
affect a banking entity’s obligation to comply with
additional or different requirements under
applicable securities, banking, or other laws.
1480 See proposed rule § ll.6(d).
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foreign trading activities.1481 For
instance, many commenters stated that
the proposal’s prohibition on trading
activities that have any connection to
the U.S. was not consistent with the
purpose of section 13 of the BHC Act
where the risk of the trading activity is
taken or held outside of the United
States and does not implicate the U.S.
safety net.1482 These commenters argued
that, since one of the principal purposes
of section 13 of the BHC Act is to limit
the risk posed by prohibited proprietary
trading to the federal safety net, the
safety and soundness of U.S. banking
entities, and the financial stability of the
United States, the exemption for foreign
trading activity should similarly focus
on whether the trading activity involves
principal risk being taken or held by the
foreign banking entity inside the United
States.1483
Many commenters argued that the
proposal’s transaction-based approach
to implementing the foreign trading
exemption would harm U.S. markets
and U.S. market participants. For
example, some commenters argued that
the proposed exemption would cause
foreign banks to exit U.S. markets or
shrink their U.S.-based operations,
thereby resulting in less liquidity and
greater fragmentation in markets
without producing any significant
offsetting benefit.1484 Commenters also
asserted that the proposal would impose
significant compliance costs on the
foreign operations of foreign banking
entities and would lead to foreign firms
refusing to trade with U.S.
counterparties, including the foreign
operations of U.S. entities, to avoid
compliance costs associated with
relying on another exemption under the
proposed rule.1485 Additionally,
commenters argued that the proposal
represented an improper extraterritorial
application of U.S. law that could be
found to violate international treaty
obligations of the United States, such as
those under the North American Free
Trade Agreement, and might result in
retaliation by foreign countries in their
1481 See, e.g., IIB/EBF; ICI Global; ICI (Feb. 2012);
Wells Fargo (Prop. Trading); BoA.
1482 See IIB/EBF; Ass’n. of Banks in Malaysia;
EBF; Credit Suisse (Seidel); Cadwalader (on behalf
of Thai Banks).
1483 See BaFin/Deutsche Bundesbank; ICSA; IIB/
EBF; Allen & Overy (on behalf of Canadian Banks);
Credit Suisse (Seidel); George Osbourne.
1484 See ICE; ICI Global; BoA; Citigroup (Feb.
2012); British Bankers’ Ass’n.; IIB/EBF.
1485 See BaFin/Deutsche Bundesbank;
Norinchukin; IIF; Allen & Overy (on behalf of
Canadian Banks); ICFR; BoA; Citigroup (Feb. 2012).
As discussed below in Part IV.C. of this
SUPPLEMENTARY INFORMATION, other parts of the final
rule address commenters’ concerns regarding the
compliance burden on foreign banking entities.
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treatment of U.S. banking entities
abroad.1486
a. Foreign Banking Entities Eligible for
the Exemption
The statutory language of section
13(d)(1)(H) provides that, in order to be
eligible for the foreign trading
exemption, the banking entity must not
be directly or indirectly controlled by a
banking entity that is organized under
the laws of the United States or of one
or more States. The proposed rule
limited the scope of the exemption to
banking entities that are organized
under foreign law and, as applicable,
controlled only by entities organized
under foreign law.
Commenters generally supported this
aspect of the proposal.1487 However,
some commenters requested that the
final rule be modified to allow U.S.
banking entities’ affiliates or branches
that are physically located outside of the
United States (‘‘foreign operations of
U.S. banking entities’’) to engage in
proprietary trading outside of the
United States pursuant to this
exemption.1488 These commenters
argued that, unless foreign operations of
U.S. banking entities are provided
similar authority to engage in
proprietary trading outside of the
United States, foreign operations of U.S.
banking entities would be at a
competitive disadvantage abroad with
respect to foreign banking entities. One
commenter also asserted that, unless
foreign operations of U.S. banking
entities were able to effectively access
foreign markets, they could be shut out
of those markets and would be unable
to effectively manage their risks in a safe
and sound manner.1489
As noted above, section 13(d)(1)(H) of
the BHC Act specifically provides that
its exemption is available only to a
banking entity that is not ‘‘directly or
indirectly’’ controlled by a banking
entity that is organized under the laws
of the United States or of one or more
States.1490 Because of this express
statutory threshold requirement, a
foreign subsidiary controlled, directly or
indirectly, by a banking entity organized
under the laws of the United States or
1486 See Norinchukin; Cadwalader (on behalf of
Thai Banks); Barclays; EBF; Commissioner Barnier;
´ ´ ´ ´
Ass’n. of German Banks; Societe Generale; Chamber
(Dec. 2012).
1487 See Sens. Merkley & Levin (Feb. 2012)
(arguing that the final rule’s foreign trading
exemption should not exempt foreign affiliates of
U.S. banking entities when they engage in trading
activity abroad); See also Occupy; Alfred Brock.
1488 See Citigroup (Feb. 2012); Sen. Carper; IIF;
ABA (Keating); Wells Fargo (Prop. Trading); Abbot
Labs. et al. (Feb. 14, 2012).
1489 See Citigroup (Feb. 2012).
1490 See 12 U.S.C. 1851(d)(1)(H).
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one of its States, and a foreign branch
office of a banking entity organized
under the laws of the United States or
one of the States, may not take
advantage of this exemption.
Like the proposal, the final rule
incorporates the statutory requirement
that the banking entity conduct its
trading activities pursuant to sections
4(c)(9) or 4(c)(13) of the BHC Act.1491
The final rule retains the tests in the
proposed rule for determining when a
banking entity would meet that
requirement. The final rule provides
qualifying criteria for both a banking
entity that is a qualifying foreign
banking organization under the Board’s
Regulation K and a banking entity that
is not a foreign banking organization for
purposes of Regulation K.1492
Section 4(c)(9) of the BHC Act applies
to any company organized under the
laws of a foreign country the greater part
of whose business is conducted outside
the United States, if the Board by
regulation or order determines that,
under the circumstances and subject to
the conditions set forth in the regulation
or order, the exemption would not be
substantially at variance with the
purposes of the BHC Act and would be
in the public interest.1493 The Board has
implemented section 4(c)(9) as part of
subpart B of the Board’s Regulation
K,1494 which specifies a number of
conditions and requirements that a
foreign banking organization must meet
in order to act pursuant to that
authority.1495 The qualifying conditions
and requirements include, for example,
that the foreign banking organization
demonstrate that more than half of its
final rule § ll.6(e)(1)(ii).
ll.6(e)(2) addresses only when a
transaction will be considered to have been
conducted pursuant to section 4(c)(9) of the BHC
Act. Although the statute also references section
4(c)(13) of the BHC Act, the Board has to date
applied the general authority contained in that
section solely to the foreign activities of U.S.
banking organizations which, by the express terms
of section 13(d)(1)(H) of the BHC Act, are unable
to rely on the foreign trading exemption.
1493 See 12 U.S.C. 1843(c)(9).
1494 See 12 CFR 211.20 et seq.
1495 Commenters noted that the Board’s
Regulation K contains a number of limitations that
may not be appropriate to include as part of the
requirements of the foreign trading exemption. See
Allen & Overy (on behalf of Foreign Bank Group);
HSBC Life. Accordingly, the final rule does not
retain the proposal’s requirement that the activity
be conducted in compliance with subpart B of the
Board’s Regulation K (12 CFR 211.20 through
211.30). However, the exemption in section
13(d)(1)(H) of the BHC Act and the final rule
operates as an exemption and is not a separate grant
of authority to engage in an otherwise
impermissible activity. To the extent a banking
entity is a foreign banking organization, it remains
subject to the Board’s Regulation K and must, as a
separate matter, comply with any and all applicable
rules and requirements of that regulation.
1491 See
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1492 Section
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worldwide business is banking and that
more than half of its banking business
is outside the United States.1496 Under
the final rule a banking entity that is a
qualifying foreign banking organization
for purposes of the Board’s Regulation
K, other than a foreign bank as defined
in section 1(b)(7) of the International
Banking Act of 1978 that is organized
under the laws of any commonwealth,
territory, or possession of the United
States, will qualify for the exemption for
proprietary trading activity of a foreign
banking entity.1497
Section 13 of the BHC Act also
applies to foreign companies that
control a U.S. insured depository
institution but that are not currently
subject to the BHC Act generally or to
the Board’s Regulation K—for example,
because the foreign company controls a
savings association or an FDIC-insured
industrial loan company. Accordingly,
the final rule also provides that a foreign
banking entity that is not a foreign
banking organization would be
considered to be conducting activities
‘‘pursuant to section 4(c)(9)’’ for
purposes of this exemption 1498 if the
entity, on a fully-consolidated basis,
meets at least two of three requirements
that evaluate the extent to which the
foreign banking entity’s business is
conducted outside the United States, as
measured by assets, revenues, and
1496 See 12 CFR 211.23(a), (c), and (e). The
proposed rule referenced only the qualifying test
under section 211.23(a) of the Board’s Regulation K;
however, because there are two other methods by
which a foreign banking organization may meet the
requirements to be considered a qualified foreign
banking organization, the final rule incorporates a
reference to those provisions as well.
1497 This modification to the definition of foreign
banking organization is necessary because, under
the International Banking Act and the Board’s
Regulation K, depository institutions that are
located in, or organized under the laws of a
commonwealth, territory, or possession of the
United States, are foreign banking organizations.
However, for purposes of the Federal securities
laws and certain banking statutes, such as section
2(c)(1) of the BHC Act and section 3 of the FDI Act,
these same entities are defined to be and treated as
domestic entities. For instance, these entities act as
domestic broker-dealers under U.S. securities laws
and their deposits are insured by the FDIC. Because
one of the purposes of section 13 is to protect
insured depository institutions and the U.S.
financial system from the perceived risks of
proprietary trading and covered fund activities, the
Agencies believe that these entities should be
considered to be located within the United States
for purposes of section 13. The final rule includes
within the definition of State a commonwealth,
territory or possession of the United States, the
District of Columbia, the Commonwealth of Puerto
Rico, the Commonwealth of the Northern Mariana
Islands, American Samoa, Guam, or the United
States Virgin Islands.
1498 This clarification would be applicable solely
in the context of section 13(d)(1) of the BHC Act.
The application of section 4(c)(9) to foreign
companies in other contexts is likely to involve
different legal and policy issues and may therefore
merit different approaches.
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5653
income.1499 This test largely mirrors the
qualifying foreign banking organization
test that is made applicable under
section 4(c)(9) of the BHC Act and
section 211.23(a), (c), or (e) of the
Board’s Regulation K, except that the
test does not require the foreign entity
to demonstrate that more than half of its
banking business is outside the United
States.1500 This difference reflects the
fact that foreign entities subject to
section 13 of the BHC Act, but not the
BHC Act generally, are likely to be, in
many cases, predominantly commercial
firms. A requirement that such firms
also demonstrate that more than half of
their banking business is outside the
United States would likely make the
exemption unavailable to such firms
and subject their global activities to the
prohibition on proprietary trading.
b. Permitted Trading Activities of a
Foreign Banking Entity
As noted above, the proposed rule
laid out a transaction-based approach to
implementing the foreign trading
exemption and provided that a
transaction would be considered to
qualify for the exemption only if (i) the
transaction was conducted by a banking
entity not organized under the laws of
the United States or of one or more
States; (ii) no party to the transaction
was a resident of the United States; (iii)
no personnel of the banking entity that
was directly involved in the transaction
was physically located in the United
States; and (iv) the transaction was
executed wholly outside the United
States.1501
Many commenters objected to the
proposed exemption, arguing that it was
unworkable and would have
unintended consequences. For example,
commenters argued that prohibiting a
foreign banking entity from conducting
a proprietary trade with a resident of the
United States, including a subsidiary or
branch of a U.S. banking entity,
wherever located, would likely cause
foreign banking entities to be unwilling
to enter into permitted trading
transactions with foreign subsidiaries or
branches of U.S. firms.1502 In addition,
1499 See final rule § ll.6(e)(2)(ii)(B). For
purposes of determining whether, on a fully
consolidated basis, it meets the requirements under
§ ll.6(e)(2)(ii)(B), a foreign banking entity that is
not a foreign banking organization should base its
calculation on the consolidated global assets,
revenues, and income of the top-tier affiliate within
the foreign banking entity’s structure.
1500 See 12 U.S.C. 1843(c)(9); 12 CFR 211.23(a),
(c), and (e); final rule § ll.6(e)(2)(ii)(B).
1501 See proposed rule § ll.6(d).
1502 See BoA; Citigroup (Feb. 2012); British
Bankers’ Ass’n.; Credit Suisse (Seidel); George
Osbourne; IIB/EBF.
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some commenters represented that it
would be difficult to determine and
track whether a party is a resident of the
United States or that this requirement
would require non-U.S. banking entities
to inefficiently bifurcate their activities
into U.S.-facing and non-U.S.-facing
trading desks.1503 For example, one
commenter noted that trading on many
exchanges and platforms is anonymous
(i.e., each party to the trade is unaware
of the identity of the other party to the
trade), so a foreign banking entity would
likely have to avoid U.S. trading
platforms and exchanges entirely to
avoid transactions with any resident of
the United States.1504 Further,
commenters stated that the proposed
rule could deter foreign banking entities
from conducting business with U.S.
parties outside of the United States,
which could also incentivize foreign
market centers to limit participation by
U.S. parties on their markets.1505
Commenters also expressed concern
about the requirement that transactions
be executed wholly outside of the
United States in order to qualify for the
proposed foreign trading exemption.
Commenters represented that foreign
banking entities currently use U.S.
trading platforms to trade in certain
products (such as U.S.-listed securities
or a variety of derivatives contracts), to
take advantage of robust U.S.
infrastructure, and for time zone
reasons.1506 Commenters indicated that
the proposed requirement could harm
the competitiveness of U.S. trading
platforms and the liquidity available on
such facilities.1507 Some commenters
stated that this requirement would
effectively result in most foreign
banking entities moving their trading
operations and personnel outside of the
United States and executing
transactions on exchanges outside of the
United States.1508 These commenters
stated that the relocation of these
activities would reduce trading activity
1503 See Cadwalader (on behalf of Singapore
Banks); Ass’n. of Banks in Malaysia; Cadwalader
(on behalf of Thai Banks); IIF; ICE; Banco de
´
Mexico; ICFR; Australian Bankers Ass’n. (Feb.
2012); BAROC.
1504 See ICE.
1505 See, e.g., RBC.
1506 See, e.g., IIF; ICE; Societe Generale; Mexican
´ ´ ´ ´
Banking Comm’n.; Australian Bankers Ass’n. (Feb.
´
2012); Banco de Mexico; OSFI. In addition, a few
commenters argued that Canadian and Mexican
financial firms frequently use U.S. infrastructure to
conduct their trading activities in Canada or
´
Mexico. See, e.g., OSFI; Banco de Mexico; Mexican
Banking Comm’n.
1507 See, e.g., ICE; Societe Generale (arguing that
´ ´ ´ ´
the requirement would impair capital raising efforts
of many U.S. companies); Australian Bankers Ass’n.
(Feb. 2012); Canadian Minister of Fin.; Ass’n. of
German Banks.
1508 See IIB/EBF.
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in the United States that supports the
financial stability and efficiency of U.S.
markets. Moreover, these commenters
argued that, if foreign banking entities
relocate their personnel from the United
States to overseas, this would diminish
U.S. jobs with no concomitant benefit.
They also contended that the proposal
was at cross purposes with other parts
of the Dodd-Frank Act and would
hinder growth of market infrastructure
being developed under the requirements
of Title VII of that Act, including use of
swap execution facilities and securitybased swap execution facilities to
enhance transparency in the swaps
markets and use of central
clearinghouses to reduce counterparty
risk for the parties to a swap
transaction.1509 For example, one
commenter represented that the
proposed exemption could make it
difficult for non-U.S. swap entities to
comply with potential mandatory
execution requirements under Title VII
of the Dodd-Frank Act and could cause
market fragmentation across borders
through the creation of parallel
execution facilities outside of the
United States, which would result in
less transparency and greater systemic
risk.1510 In addition, another commenter
stated that the proposed requirement
would force issuers to dually list their
securities to permit trading on non-U.S.
exchanges and, further, clearing and
settlement systems would have to be set
up outside of the United States, which
would create inefficiencies, operational
risks, and potentially systemic risk by
adding needless complexity to the
financial system.1511
Instead of the proposal’s transactionbased approach to implementing the
foreign trading exemption, many
commenters suggested the final rule
adopt a risk-based approach.1512 These
commenters noted that a risk-based
approach would prohibit or
significantly limit the amount of
financial risk from such activities that
could be transferred to the United States
by the foreign trading activity of foreign
banking entities.1513 Commenters also
noted that foreign trading activities of
most foreign banking entities are already
subject to activities limitations, capital
requirements, and other prudential
1509 See Bank of Canada; Banco de Mexico; Allen
´
& Overy (on behalf of Canadian Banks).
1510 See Allen & Overy (on behalf of Candian
Banks).
1511 See IIF.
1512 See BaFin/Deutsche Bundesbank; ICSA; IIB/
EBF; Allen & Overy (on behalf of Canadian Banks);
Credit Suisse (Seidel); George Osbourne.
1513 See IIB/EBF.
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requirements of their home-country
supervisor(s).1514
The Agencies have carefully
considered these comments and have
determined to modify the approach in
the final rule. The Agencies believe that
the revisions mitigate the potential
adverse impacts of the proposed
approach while still remaining faithful
to the overall purpose of section
13(d)(1)(H). Also, the Agencies believe
that section 13(d)(1)(J) of the BHC Act,
which authorizes the Agencies to
provide an exemption from the
prohibition on proprietary trading for
any activity the Agencies determine by
rule ‘‘would promote and protect the
safety and soundness of the banking
entity and the financial stability of the
United States,’’ 1515 supports allowing
foreign banking entities to use U.S.
infrastructure and trade with certain
U.S. counterparties in certain
circumstances, which will promote and
protect the safety and soundness of
banking entities and U.S. financial
stability.
Overall, the comments illustrated that
both the mechanical steps of the
specified transactions to purchase or
sell various instruments (e.g., execution,
clearing), and the identity of the entity
for whose trading account the specified
trading is conducted are important.1516
Consistent with the comments described
above, the Agencies believe that the
application of section 13(d)(1)(H) and
their exemptive authority under section
13(d)(1)(J) should focus on both how the
transaction occurs and which entity will
bear the risk of those transactions.
Although the statute does not define
expressly what it means to act ‘‘as a
principal’’ (acting as principal
ordinarily means acting for one’s own
account), the combination of references
to engaging as principal and to a trading
account focuses on an entity’s incurring
risks of profit and loss through taking
ownership of securities and other
instruments. Thus, the final rule
provides an exemption for trading
activities of foreign banking entities that
addresses both the location of the
facilities that effect the acquisition,
holding, and disposition of such
positions, and the location of the
banking entity that incurs such risks
through acquisition, holding, and
disposition of such positions.
The Agencies believe this approach is
consistent with one of the principal
purposes of section 13, which is to limit
risks that proprietary trading poses to
1514 See
1515 See
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the U.S. financial system.1517 Further,
the purpose of section 13(d)(1)(H) is to
limit the extraterritorial application of
section 13 as it applies to foreign
banking entities.1518
In addition, prohibiting foreign
banking entities from using U.S.
infrastructure or trading with all U.S.
counterparties could cause certain
trading activities to move offshore, with
corresponding negative impacts on U.S.
market participants, including U.S.
banking entities. For example,
movement of trading activities offshore,
particularly in U.S. financial
instruments, could result in bifurcated
markets for these instruments that are
less efficient and less liquid and could
reduce transparency for oversight of
trading in these instruments. In
addition, reducing access to foreign
counterparties for U.S. instruments
could concentrate risks in the United
States and to its financial system.
Moreover, the statute provides separate
exemptions for U.S. banking entities to
engage in underwriting and market
making-related activities, subject to
certain requirements, and there is no
evidence that limiting the range of
potential customers for these entities
would further the purposes of the
statute. In fact, it is possible that
limiting the customer bases of U.S.
banking entities, as well as other U.S.
firms that are not banking entities, could
reduce their ability to effectively
manage their inventories and risks and
could also result in concentration risk.
These potential effects of the
approach taken in the proposal appear
to be inconsistent with the statute’s
goals, including the promotion and
protection of the safety and soundness
of banking entities and U.S. financial
stability. To the contrary, the exemptive
approach taken in the final rule appears
to be more consistent with the goals of
the statute and would promote and
protect the safety and soundness of
banking entities and U.S. financial
stability by limiting the risks of foreign
banking entities’ proprietary trading
activities to the U.S. financial system,
while also allowing U.S. markets to
1517 See, e.g., 12 U.S.C. 1851(b)(1) (directing the
FSOC to study and make recommendations on
implementing section 13 so as to, among other
things, protect taxpayers and consumers and
enhance financial stability by minimizing the risk
that insured depository institutions and the
affiliates of insured depository institutions will
engage in unsafe and unsound activities).
1518 See, e.g., 156 Cong. Rec. S5897 (daily ed. July
15, 2010) (statement of Sen. Merkley) (stating that
the foreign trading exemption ‘‘recognize[s] rules of
international comity by permitting foreign banks,
regulated and backed by foreign taxpayers, in the
course of operating outside of the United States to
engage in activities permitted under relevant
foreign law.’’).
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continue to operate efficiently in
conjunction with foreign markets (rather
than creating incentives to establish
barriers between U.S. and foreign
markets).1519
Thus, in response to commenter
concerns, the final rule has been
modified to better reflect the text and
achieve the overall purposes of the
statute (by ensuring that the principal
risks of proprietary trading by foreign
banking entities allowed under the
foreign trading exemption remain solely
outside of the United States) while
mitigating potentially adverse effects on
competition.1520 In order to ensure these
risks remain largely outside of the
United States, and to limit potential risk
that could flow to the U.S. financial
system through trades by foreign
banking entities with or through U.S.
entities, the final rule includes several
conditions on the availability of the
exemption. Specifically, in addition to
limiting the exemption to foreign
banking entities, the final rule provides
that the exemption for the proprietary
trading activity of a foreign banking
entity is available only if:
(i) The banking entity engaging as
principal in the purchase or sale
(including any personnel of the banking
entity or its affiliate that arrange,
negotiate or execute such purchase or
sale) is not located in the United States
or organized under the laws of the
United States or of any State; 1521
(ii) The banking entity (including
relevant personnel) that makes the
decision to purchase or sell as principal
is not located in the United States or
organized under the laws of the United
States or of any State;
(iii) The purchase or sale, including
any transaction arising from riskmitigating hedging related to the
instruments purchased or sold, is not
accounted for as principal directly or on
a consolidated basis by any branch or
affiliate that is located in the United
1519 12
U.S.C. 1851(d)(1)(J).
proposed rule also contained a definition
of ‘‘resident of the United States’’ that was designed
to capture the scope of U.S. counterparties that, if
involved in the transaction, would preclude that
transaction from being considered to have occurred
solely outside the United States. The final rule
addresses this point by including a definition, for
purposes of § __.6(e) only, of the term ‘‘U.S. entity.’’
1521 Personnel that arrange, negotiate, or execute
a purchase or sale conducted under the exemption
for trading activity of a foreign banking entity must
be located outside of the United States. Thus, for
example, personnel in the United States cannot
solicit or sell to or arrange for trades conducted
under this exemption. Personnel in the United
States also cannot serve as decision makers in
transactions conducted under this exemption.
Personnel that engage in back-office functions, such
as clearing and settlement of trades, would not be
considered to arrange, negotiate, or execute a
purchase or sale for purposes of this provision.
1520 The
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5655
States or organized under the laws of
the United States or of any State;
(iv) No financing for the banking
entity’s purchase or sale is provided,
directly or indirectly, by any branch or
affiliate that is located in the United
States or organized under the laws of
the United States or of any State; 1522
(v) The purchase or sale is not
conducted with or through any U.S.
entity,1523 other than:
(A) A purchase or sale with the
foreign operations of a U.S. entity, if no
personnel of such U.S. entity that are
located in the United States are
involved in the arrangement,
negotiation or execution of such
purchase or sale.
The Agencies believe it is appropriate
to exercise their exemptive authority
under section 13(d)(1)(J) to also allow,
under clause (vi) of the final rule, the
following types of purchases or sales
conducted with a U.S. entity:
(B) A purchase or sale with an
unaffiliated market intermediary acting
as principal,1524 provided the purchase
or sale is promptly cleared and settled
through a clearing agency or derivatives
clearing organization acting as a central
counterparty; or
(C) A purchase or sale through an
unaffiliated market intermediary,
provided the purchase or sale is
conducted anonymously (i.e. each party
to the purchase or sale is unaware of the
identity of the other party(ies) to the
purchase or sale) on an exchange or
similar trading facility and promptly
cleared and settled through a clearing
agency or derivatives clearing
organization acting as a central
counterparty.
The requirements are designed to
ensure that any foreign banking entity
engaging in trading activity under this
exemption does so in a manner that
ensures the risk, decision-making,
arrangement, negotiation, execution and
financing of the activity resides solely
outside the United States and limits the
risk to the U.S. financial system from
trades by foreign banking entities with
or through U.S. entities.
The final rule specifically recognizes
that, for purposes of the exemption for
1522 This provision is not intended to restrict the
ability of a U.S. branch or affiliate of a foreign
banking entity to provide funds collected in the
United States to its foreign parent for general
purposes.
1523 ‘‘U.S. entity’’ is defined for purposes of this
provision as any entity that is, or is controlled by,
or is acting on behalf of, or at the direction