In my previous post on the Volcker Rule, I admittedly glossed over the real issue in my second prediction. This issue is important, but it’s also reasonably complex (way too complex for some people, I suspect), and it requires some context and explanation to fully appreciate.

The statutory text of the Volcker Rule contained a glaring flaw: the statute prohibited proprietary trading by basically defining everything as “proprietary trading,” and then carving out exemptions for everything else. This was a colossal mistake for a variety of reasons, but the most important reason is that rather than having the regulators simply define “proprietary trading,” it put the regulators in the position of having to define every form of legitimate trading that banks do — underwriting, market-making, hedging, etc. Obviously, that’s a much, much more difficult task, and one that’s significantly more likely to lead to problems due to gaps — whether intended or unintended — in the proposed rule’s exemptions. It’s hardly a targeted solution to the problem of government-backed prop trading, to say the least. (I imagine the ultimate blame for this lies with someone in the Legislative Counsel’s office, although Merkley and Levin’s offices bear some blame here too, as they were clearly in way over their heads during this entire process.)

‘Flipping the Presumption’

The upshot of this is that it creates a presumption that all trades are prohibited prop trades, unless proven otherwise. What the banks want to do is to flip the presumption — instead of regulators scrutinizing whether each trade falls into one of the nine “permitted avtivities” exemptions, regulators would be scrutinzing whether each trade is a prohibited prop trade.

Whether flipping the presumption would dilute the strength of the ban on prop trading depends entirely on the quantitative and qualitative metrics that regulators ultimately use to identify prohibited prop trades. The right metrics would appropriately identify prohibited prop trades, while the wrong metrics could either identify too many trades as prop trades, or too few. But that’s where the debate would shift — or rather, should shift — if the regulators flipped the presumption. (The metrics described in the proposed Volcker Rule would, if anything, be overinclusive, and would require the regulators to apply some judgment to flagged trades — which I think is appropriate.)

Now, regulators only have so much discretion here. The statute is the statute, and flawed though it may be, regulators still have to work within its confines. But there are ways to effectively flip the presumption.

One way to do this is to define the main exemptions (market-making, hedging, and underwriting) very broadly, but include a carve-out for trades done for the “trading account” — which is, bizarrely, where the real definition of proprietary trading is located in the statute. The effect of this would be to allow regulators to focus on whether a bank’s trades exhibit the characteristics of trades done for the “trading account” (i.e., prop trades), based on the quantitative and qualitative metrics the regulators have identified, rather than focusing on whether each trade can fit into one of the defined exemptions. In other words, the presumption would be that a trade falls into the market-making or hedging exemptions, unless the regulators believe otherwise.

This is basically what I predicted the regulators would do in my previous post — although, crucially, I limited my prediction to the market-making exemption, and I said that the regulators would make this an “alternative” market-making test. A broader market-making exemption with a metrics-heavy carve-out for prohibited prop trading would go a long way toward: (a) alleviating concerns about the Volcker Rule’s impact on market-making without necessarily diluting the prop trading ban; and (b) making the regulators’ task a lot less daunting, and a lot less likely to cause unforeseen and unintended disruptions to the financial markets.


Rick Damaini said...

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Anonymous said...

Amen. Banks should be banks, not trading houses, and bankers should be bankers, not traders. Bankers should cease speculation with depositors money, and divest any trading operaion to the vagaries of the market.

James Wade said...

We now know that there was a very good reason for separating retail banking from investment (or"merchant") banking. Taxpayers took it on the chin. Now the big "financial institutions" (far grander and more toxic than any mere "bank") want to, and are doing, more and more of the same. The Volker Rule will cause them a certain amount of inconvenience, but in the long run, since they have favored access to the best Congress that money can buy, they will avidly pursue self-interested trading and profit. "Stakeholders" and customers will take what crumbs they are thrown.

Conscience of a Conservative said...

The Banks know exactly what is proprietary trading and what isn't. Paul Volcker stated this from the beginning, and all reasonable people know this. The regulation fails in that it's attempting to be too precise which can only be to the advantage of those gaming the rules.

Anonymous said...

While the point is well taken, I am not at all clear as to the utility of this post at this point.

Federal Reserve Board, FDIC, SEC and OCC have jointly promulgated their proposed Volcker Rule. That was more than a month ago, and comments have been coming from all directions.

Most notably, the comment letter filed by Occupy the SEC, in a 325-page missive, addresses this and many other, equally, if not more, urgent issues. Annexure B to the comment letter even lists suggested changes.

AHodge said...

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all of these comments make me sad with how stupid people are.

and the poster who mentions the occupy sec 325 page letter? It has some of the dumbest most toxic thoughts of all.

Perhaps you all should seek a deeper understanding of the finance world before you all spew around your worthless uneducated comments.

Reg Reform is a good thing and was needed. Shot-gun wedding reg reform is not.

Fusion said...

I don't think that the Occupy SEC letter is "stupid." Did Anonymous bother to read it before reviling it as containing "some of the dumbest most toxic thoughts of all" ?
Exactly what in the letter's content is dumb and toxic?

Its annoying when people pour out condescension on those with whom they disagree but fail to identify the errors in the opposing party's argument. Dear Anonymous: consider reading the Occupy SEC letter. Maybe then you can tell us why you find it so toxic. On the other hand, you might find many points on which you agree with them. You'll never know unless you read it.

Anonymous said...

I actually have read the entire paper from start to finish as well the dozens to hundreds of other comment letters on the proposed rules. Most comment letters are a couple of pages in length and fairly straight to the point... versus 325 pages!!!

When commenting on a rule in question, comment on the rule in question. Don't use 325 pages to bitch about the financial system as a whole and things that don't even pertain to the very specific detailed rule you are commenting on.

I would happily discuss why many of the points are toxic but frankly I think that there a limit on how long these posts can be.

If you don't work in the industry on a day to day basis I find it laughable that people think that they can add value to it when they know NOTHING about it.

I find it very much similar to:
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Reading through comments and hearing wrong they are about Repo, reserve ratios etc is just painful and frustrating.

Finally as it pertains to specifics points, reading it once was painful enough.. if they had half a bit of intelligence and typed up something that was palatable I would happily re-read and tell you why they are so fucking stupid and misguided in their thoughts

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Exactly what is so toxic in Occupy SEC's letter. If you have read, as you claim you have, please identify and specify what is toxic. Exactly what idea have they proposed that has upset you so much?

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Defining the rules in the "everything is disallowed unless and until we say otherwise" manner may have been done to prevent future, as yet undesigned and undeveloped trading activities, from being allowed until due consideration could be given to them. Admittedly, such rules could end up being (temporarily) more restrictive than absolutely necessary, but at least are much more future-proof.

If the rules merely explicitly disallowed an explicitly enumerated set of *specific* patterns of trading, then those organisations that wanted to avoid all restrictions could concievably invent new trade structures to circumvent the restrictions - not a good outcome.

Perhaps Congress was just opting for the lesser of two evils...

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