Banking entities that will be required to conform to the upcoming Volcker Rule should start focusing on the existing compliance programs and procedures they already have in place to set the tone for the tiered programmatic compliance regime that will be mandated by the rule later, say regulatory compliance experts at Deloitte & Touche.
They say the first step banking entities can take now is to clearly identify which existing activities are covered by the rule. Next, they should map trading and funds activity to exemption criteria defined in the proposed rule at the trading desk level and analyze the trading and revenue effects of the proposed rule. Lastly, banking entities should conduct evaluations on tiered compliance programs, quantitative metrics, and reporting requirements.
