We have consistently questioned the necessity and efficacy of the Volcker Rule and believe that its full repeal is the only way to avoid the harm that it would do to the economy, bank customers, and the banking industry. 

The American Bankers Association officially urged repeal of the Volker Rule in a September 7, 2012 letter to Rep. Spencer Bachus, chair of the House Financial Services Committee.  Citing the struggles the regulators have had in crafting the rules, the ABA stated that the restrictions on Banks' proprietary trading contemplated by Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act are unworkable, and ultimately harmful to the banking industry. The ABA also asserts that the Volker Rule relies on poorly defined terms and vague concepts, and fundamentally fails to address its purported objective of prohibiting excessively risky proprietary trading and investment activities.

 

A discussion paper published on August 10, 2012 by a team commissioned by the UK Treasury's Chancellor of the Exchequer takes a look at the structure and governance of LIBOR and the corresponding criminal sanctions regime. This initial discussion paper identifies the failures within the current LIBOR processes, explores the options to strengthen LIBOR, considers whether LIBOR could or should be replaced by alternative benchmarks, and looks into whether the issues raised with respect to LIBOR are relevant to other benchmarks in financial and other markets.  Martin Wheatley, Managing Director of the UK Financial Services Authority and Chief Executive Designate of the Financial Conduct Authority (one of the successor organizations to the FSA) was directed to perform this review and report back to HM Treasury with recommendations.

Just in time for the CFTC and SEC's final swaps provisions,  State Street and TABB Group have published a paper, "Charting New Territory: Buy-Side Readiness for Swaps Reforms," based on a survey of buy-side firms examining where the investment community stands on a range of issues arising from global swaps reforms.  The paper also looks at the challenges the industry faces as it transforms from an opaque, over-the-counter, bilaterally traded environment to electronic execution and central clearing.