Data Boiler Technologies, LLC - Addendum Volcker Revision Comments
Watered-down Proposals Watered-down Excuses
TOB
Carve-out Tender Option Bond (TOB) Trust
Banks should be permitted to retain their
investments in Small Business Investment
Companies (SBICs) that surrender their
licenses during wind-down phase
SBIC
Permit Fund of Funds investment in SBIC
Covered Funds
Make Bank Owned Life Insurance (BOLI)
exposures to a basket of hedge funds not a
violation.
BOLI
BOLI exclusion will not be violated purely as invest in structured notes that included underlying exposures to a
a consequence of policies issued to both
bank & non-bank entities in same separate
account
Carve-out Cash Collateral Pools (CCP) &
clarification either the CCP are not
construed as "banking entities" under the
Proposal or that CCP are included in the
securities lending exemption from the
CCP
definition of "trading account"; inclusion of
CCP in the "customer fund" exemption;
Exemption of CCP including those under
Super23A, pursuant to the 13(d)(I)(J) of
BHC Act
- Exclude "qualify foreign excluded funds"
from banking entity definition
Fund-of-One
- Exclusion of qualifying funds-of-one from
the definition of wholly-owned subsidiary
- Carved out from the wholly-owned
subsidiary definition so that their non-bank
managers are not rendered subject to
Volcker compliance
This addendum should be read in conjunction with the open letter submitted to the OCC regarding Volcker Revision, see http://www.databoiler.com/index_htm_files/DataBoiler%20Volcker619%20Comments.pdf
Available Exemption Our Comments
TOB can be exempted under JV structure if:
- =<10 unaffiliated co-venturers
248.10(c)(2)/(3), FAQ#15 - JV engaging in activities other than investing in securities for resale or other
- JV exclusion is not met by an issuer that raises money from a small number of disposition
Always par plus accrued interest and the structure of the
investors primarily for the purpose of investing in securities; - JV is not, and does not hold itself as being, an entity or arranagement that
contractual liquidity obligation make it clear the P&S in
- The Rule intended to prevent the JV exclusion from being used as a vehicle to raises money from investors primarily for the purpose of investing in
connection with TOB trusts are not undertaken for purpose of S-T
raise funds from investors primarily for the purpose of profiting from securities for rsale or other disposition or otherwise trading in securities
resale
investment activity in securities for resale or other disposition or otherwise
trading in securities. Volcker permits banking entity to provide the TOB with credit or liquidity
enhancement if the bank participates in the program only as an unaffiliated
3rd party (no relationship with TOB sponsor) ...
Bank investors could lose their SBIC exemption at exactly the
Surrender license doesn't necessary mean the small business has prospered,
time when profits are being realized and setting their stake in the
it could also be failure, or simply not meeting (or not wanting to comply)
secondary market would be least liquid because of the short time 248.10(c)(11)
with SBA.gov criteria. This is a commercial decision on the bank side to seek
left in the fund they may need to engage in a regulatory-forced Verify if SBIC (license#)/ Public Welfare Investment Funds (12USC24 CRA/
exit strategy. Volcker Rule is in no position to skew regulatory policy to
fire sale or withdrawal of their interest from the fund (oftentimes Qualified Rehabilitation Expenditures (IRC47) met exclusion
ensure commercial profitability.
at values below current valuations) in order to avoid being our of
compliance.
Volcker never prohibits banks from direct lending to small businesses. Why
frequently buying & selling these SBIC funds? If banks only act as sponsors
while incapable to lend directly to small businesses, does the economy still
Allow banks to use professionals rather than making the banks
banking entitys investment in the fund of funds must "also meet the need banks to seat in the middle?
have this investing expertise in house allow a greater risk
investment limitations contained in __.12 of the rule text" - borrow short, lend long (vs ALM maturity match )?
diversification via the portfolio effect.
- when incapable grasp hold of too much resources ...
No, OCC IL 1030 was written in May 2005 (i.e. 10+ years before Volcker is
248.10(c)(7) separate account
effective). IL 1030 indeed exposes concern about "speculative" practice
used solely for the purpose of BOLI (BE(s) is beneficiary), provided no banking
through BOLI and stated that "the variable portion of the return is more
OCC Interpretive Letter (IL) 1030 prided a path for banks to entity that purchases the policy:
similar to the return of
- controls the investment decisions regarding the underlying assets or holdings
shares of an IC invested in hedge funds or equities...". Bank ownership of
a basket of hedge funds. of the separate account; or
and relationship with hedge funds is tighten ever since the Volcker covered
- participates in the P&L of the separate account other than in compliance with
funds provision. So, the process should continue require supervisory "non-
applicable supervisory guidance
objection" by the bank's examiner-in-charge on case-by-case basis ...
79 Fed Reg 5710 and n.2030
may be operated as common trust funds reliance on 40 Act 3(c)(3)
Securities lending
Offered as an adjunct to it custodial service would qualify as a common trust
- Sponsoring, serving as trustee 248.10(d)(2)
fund under Reg 9
Agent banks generally have a general partnership, LLC - Verify if Cash Collateral Pools may rely on sections 3(c)(1) and 3(c)(7) of the 40
membership, or trustee interest such interest could be Act to avoid being an Investment Company (IC)
OCC Interpretive Letter#865
deemed to constitute "sponsorship" As to the purpose to limit - register CCP with the SEC as IC, or to operate pools as separate accounts to
"the bank proposed to enter into a trust agreement with each of its
potential conflicts of interest, acts as fiduciaries to securities exclude from the covered fund definition
customer that wished to lend its securities, under which the bank would act
lender in manaing the cash collaterla pools they must comply
as trustee and the owner/lender of the securities would be settlor and
with the provision of 12 CFR part 9...
beneficiary. The bank would retain discretion to manage the collateral on a
pooled onr non-pooled basis ...
Fund-of-one is owned by a single investor and that allows the A wholly-owned subsidiary of a banking entity, although excluded from the
investor to have customized terms ... a fund-of-one whose sole definition of covered fund, still would itself be a banking entity. There is no
owner is a foreign bank is considered a wholly-owned subsidiary good way out for Fund-of-One, except to divest.
of the foreign bank and, therefore, ineligible for covered fund Neither 248.10(c)(2) "wholly owned subsidary" exclusion nor SOTUS exemption
status. As such, it is deemed a banking entity (non-bank manager (FAQ#13) would work in this situation Alternatively, restructure the fund that it'll qualify for SOTUS exemption.
responsible for the fund daily management) is subject to Volcker There should be covenants to ensure that fund maintains its covered fund
compliance obligation A SOTUS fund may not be a "wholly status and that the SOTUS fund does not become a wholly-owned subsidiary
owned subsidiary" of a banking entity. of the foreign bank ...
Page 1 of 4

Watered-down Proposals
Revise definition that the right of a debt
security holder to participate in the removal
or replacement of an investment manager
for cause is not an ownership interest
Re-examine "covered fund" definition
CLO
3(c)(1)/(7) exemption inclusion of
securitization vehicles to consider that
issuers of Collateralized Loan Obligations
(CLOs) have been the single largest source of
capital for syndicated loan financing for US
companies
Covered Funds - Securitization
Carve-out new investment in Collateral Debt Some securitized debt obligations trade and price like securitized - The banking entity reasonably believes that the offering proceeds received by
CDO
Obligations (CDO) backed by Trust Preferred fixed income products shouldn't be covered fund because they
Securities (TruPS)
Modify the qualifying asset backed
ABCP
commercial paper (ABCP) conduit"
This addendum should be read in conjunction with the open letter submitted to the OCC regarding Volcker Revision, see http://www.databoiler.com/index_htm_files/DataBoiler%20Volcker619%20Comments.pdf
Data Boiler Technologies, LLC - Addendum Volcker Revision Comments
Watered-down Excuses
The category of exempt loan securitizations is so narrowly
circumscribed that virtually all CLOs fall within the definition of
"covered funds" - only those securitizations comprised solely of
loans and certain related servicing or hedging interests, while
Legacy CLOs held cash and S-T investments for re-balancing +
small amount of corporate bonds.
For-cause voting rights have none of the characteristics of equity
or partnership interests ... bear no resembalnce to HFs and PEFs
... no residual claim to the issuer's assets ... do not receive
income on a pass-through basis or by reference to underlying
performance ... do not share in the risk ... also do not have
"synthetic rights" to any of these ownership characteristics.
Creditor rights designed to protect their debt interests ....
contingent right to participate in the removal of the manager for
cause ... do not have the right to vote on establishing the issuer's
objectives and policies, electing its BOD, or controlling the
decisions of the manager ...
are exempt from 40 Act registration by virtue of 3(c)(1)/(7)
- So that it does not require the advising banking entity to
assume all risk associated with the securities issued
- othewise may be useful to more customer-facing bank
sponsored ABCP issuers.
Available Exemption Our Comments
Nothing in Volcker is construed to limit or restrict the ability of a banking
entity or nonbank financial company ... to sell or securitize loans in a manner
otherwise permitted by law. However, abusive use of securitization in a
248.10(c)(8) maner impermissible by law is a different story.
- Verify if assets & holdings of the issuers comprised solely of permissible
interest rate derivatives or Foreign Exchange derivatives Legacy CLOs problem: 5-10% Bond Bucket
- Verify if assets & holdings of the issuers comprised solely of Special Unit of - poor quality corporate bonds mixed in with good quality loans, while policy
Beneficial Interest (SUBIs) and Collateral Certificates direction urges banks to divest those poor quality assets.
- Verify if assets & holdings of the issuers comprised solely of directly held loan - Per OCC analysis of 12 CFR Part 44, a fire sale would reduce prices by 5.5%,
- Verify if assets & holdings of the issuers comprised solely of cash equivalents so banks can at least expect $3.6 billion from the required divertiture of
and securities received in lieu of debts previously contracted impermissible assets, such as CLO notes.
- Verify if assets & holdings of the issuers comprised solely of other servicing - Also, hedge agreement must relate to assets & reduce interest rate or FX
assets that display characters of cash equivalents risks
FAQ#4 Almost always sold in Rule 144A and Reg S using 3(c)(7) many CLO
any servicing asset that is a security must be a permitted security under provide rights to a "controlling class" of senior debt security holders in
248.10(c)(8)(iii) designation of investment managers, creating the potential to hold
"ownership" interest. This can be addressed by:
- controlling class waiver
- issuance of non-voting sub-class ...
FAQ#21
- If a banking entity acts as a market maker with respect to interests in a
Qualifying TruPS CDO that is a covered fund, then section 248.11(c) of the
248.16(a) allows the retention of an interest in or sponsorship of covered funds
final rule makes the capital deduction provision in section 248.12 applicable
by banking entities if, among other things, the following conditions are met:
to those interests.
- The TruPS CDO was established, and the interest was issued, before May 19,
- If a banking entity relies on section 248.12 to hold an interest in a TruPS
2010;
CDO that is a covered fund but is not a Qualifying TruPS CDO, the banking
entity would be required to comply with all the limits and restrictions in
the TruPS CDO were invested primarily in qualifying TruPS collateral issued by
section 248.12, including the requirement to deduct its investment from its
banking entities; and
tier 1 capital for purposes of determining compliance with applicable
- The banking entitys interest in the TruPS CDO was acquired on or before
regulatory capital requirements.
December 10, 2013, the date the Agencies issued the Final Rule implementing
the Volcker Rule.
TruPS are illiquid. Permitting not to divest does not mean allowing new
...
investment in TruPS CDO. 2014 Bankruptcy court decision in the case of FMB
Bancshares Inc. v. Trapeza CDO XII, LTD. exposes issues with TruPS that
endanger community banks ...
Although ABCP may be repaid in the ordinary course from the proceeds of
newly issued commercial paper or from draws on a liquidity facility, but
most single-seller conduits are extendible. They can extend past the original
maturity date if they are unable to roll the ABCP at maturity.
248.10(c)(9)
Per Basel III Liquidity Coverage Ratio requirement, ABCP or other securities
- Issue only ABS comprised of a residual inerest and ABS <397 days
issued by a bank sponsored conduit might require support from High Quality
- Hold only permissible assets for a loan securitization
Liquid Assets (HQLA)
- Initial issuance, no secondary market purchases
beyond the level of any commitments from the sponsoring bank, unless 'the
- Commitment to provide 100% and unconditional liquidity coverage
bank can demonstrate it can not be required to provide such support and it
is not subject to market expectations, reputation concerns, or other
considerations that might motivate implicit support for the outstanding
debt'. Hence, 100% unconditional liquidity coverage is essentially a credit
enhancement for the assets ...
Page 2 of 4
 Data Boiler Technologies, LLC - Addendum Volcker Revision Comments

Watered-down Proposals Watered-down Excuses Available Exemption Our Comments

Absence of Price Risk
Do not add to the systemic risk of financial system. As with
Lure customers into illiquid, complex, & hard to untangle derivative contracts
exempted riskless prinicipal trades, MBT merely intermediate risk
may possibly violate banks' fiduciary responsibilities. Attempts to bypass Price risk shifted to upstream banks, but these banks don't necessarily have
from nonfinancial customers to the dealrer market they shift
controls through a flipping-switch between client versus counterparty may better way to manage it. Yet it gives rise to credit & liquidity risks that can
price risk to upstream dealer banks with substantial number of
constitute as possibly become systemic risk to the overall financial system.
alternative ways to manage price risk/ significant resources at
willful violation.
their disposal.
Volcker's scope about banking entities is much broader than market risk
MBT/ LLH/ Customer-Driven Derivatives

Customers: capital rule, thus the two rules aren't equivalent.

Bona Fide Hedging Only
- fiduciary capacity for a customer
Do not directly affect the trasacting financial institution's income
- Transaction is conducted for the account of, or on behalf of customer New risk may be introduced in the process of reducing price risk. Banks
or capital (never owns the underlying or it has an offsetting
- Banking entity does not have or retain beneficial ownership of the instruments should cautiously enter into hedges instead of constant flipping between
transaction that absorbs any change in value).
- riskless princial buy/ sell hedges. Incorrect tagging of trades to wrong categories of
Carve-out Matched Book Trading (MBT), exemption may be excusable if the matter is only an isolated incident, but
Customer-driven
Loan Level Hedging (LLH), including in FX Counterparty: regulators should thoroughly investigate any habitual or willful act to dodge
Bank's 2nd LOD risk control professionals independently check
forwards and options, agricultural _.5(b) Risk-mitigating hedge exemption regulatory oversight fictitious hedges in particular.
each trade's suitability. Traders are not able to "front-run" such
commodity derivatives and energy - _.5(b)(1)(ii) on-going monitoring,
trades, or take advantage of the customer position in any other
commody deriviates, ASC815 derivatives - (iii) independent testing such correlation analysis demonstrates , Slick practices in the 2011 UBS $2.3 billion trading loss case and 2012 JPMC
way because trades are matched. Part of custodial securities
that are desinated as accounting hedges, - (2)(ii) At the inception of the hedging activities, $6.2 billion trading loss case have tarnished the trustworthiness of the
lending services.
with no requirement to rebut the - (iv)(C) Requires ongoing recalibration. banking sector to reliably assess risks and to provide accurate, complete,
presumption of trading. [Blame UBS/JPMC cases for the burden!!] and timely information to the regulators. 2013 Senate report exposes issues:
Congress did not create Volcker to restrict or prohibit Credit risk
mischaracterized high risk trading as hedging, hid massive losses,
management, which MBT can generate credit risk & liquidity risk
Allow Reverse Presumption on Trades Banks must NOT mischaraterize MBT/LLH/ the like products under the guise of disregarded risk, dodged OCC oversight"
(margin requirements on one side of a MBT is not offset by
Proprietary Trading Ban

Reducing Risk on non-Trading Assets, such market-making exemption. These activities aren't related to market-making
margin calls on the other).
as Mortgage Servicing (MS) Assets, provided functions - routinely stand ready to purchase and sell financial instruments Banks ought to strictly follow _.5(b) ...
there will be back-testing explaining related to the trading desk's financial exposure.
Consistent with the Federal Reserve Board's market risk capital
deivations from expectation and set
rule.
toleratnces for projected change in value
under stress conditions.
_.3(d)(3) Liquidity management exemption
Carve-out activities that bear no price risk - trading in accordance to documented liquidity management plan
or that reduce price risk to non-trading - specifically authorize the particular securities* to be used, the The Final Rule determined NOT to expand the liquidity management
assets, irrespective of the quantity of amount, types and risks of these securities that are consistent with provision to broadly allow asset-liability management (ALM), earnings
financial instruments used. liquidity management and the circumstances in which the particular management, or scenario hedging, and declining to add a separate exclusion
Reduce Price Risk
securities may or must be used; or exemption. See Footnote 224, 225, 239 (section 165(b)(1)(A)(ii) of the
With non-trading assets and liabilities having second order risk
Remove "purpose test" to revise definition (sensitivities to interest rates change as rates move), holding a - require that the transaction authorized be principally for the purpose Dodd-Frank Act; Enhanced Prudential Standards, 77 FR 644 at 645 +
of "trading account", including carve-out of hedge has economic cost. of liquidity management and not for short-term trading purposes; Enhanced Prudential Standards, 77 FR 76,678 at 76,682)
securities positions that are carried as either - require that any securities purchased or sold be highly liquid
available-for-sale at fair value or held-to- and limited to securities that are not reasonably expected^ to The Rule's preamble notes that trading account is nomenchlature for the set
Agency securities and interest rate swaps are among the two
MS / ALM

maturity at amortized cost.
most ccommon tools used to manage the interest rate risk
associated with MS rights.
Swaps likely would fail purpose test because:
- Short-term resale (60-day rebuttable presumption)
- Benefitting from actual or expected short-term price
movements/ realizing short-term arbitrage profits
- Hedging one or more such positions.
give rise to appreciable profits or losses as a result of short-term
price movements;
- limit any securities (together with any other instruments purchased
or sold for liquidity management purposes) to an amount that is
consistent with the banking entitys near-term funding needs
~ If the trade doesn't fit above criteria, see if it qualifies for _.5(b) risk
mitigating hedging exemption.
* The U.S. implementation of a quantitative liquidity coverage ratio as part of
the Basel III capital and liquidity framework.
^ the timing of purchases and sales, the types and duration of positions taken ...
... must all indicate that managing liquidity, and not taking short-term profits (or
limiting short-term losses), is the purpose of these activities ...
of transactions that are subject to the restriction on proprietary trading.
2012 JPMC case exposes issues that OCC regulatory oversight was dodged by
the bank's sharing of "incomplete" trading account information to hide
massive loss. Hence, Volcker's purpose test must be preserved.
Continue to use U.S. Treasury or other permissible agency bonds to manage
interest rate risk associate with MSR. A banking entity could enter into an
interest rate swap to hedge against a specific portfolio of loans, but can no
longer engage in the general macro hedging activities that do not relate to
individual or aggregated positions that have specific, identifiable risk(s).

This addendum should be read in conjunction with the open letter submitted to the OCC regarding Volcker Revision, see http://www.databoiler.com/index_htm_files/DataBoiler%20Volcker619%20Comments.pdf Page 3 of 4
 Data Boiler Technologies, LLC - Addendum Volcker Revision Comments

Costs to bring banks' activities into conformance with the implementing Volcker, including in building, maintaining, monitoring and audting the required, expansive compliance program.
Inferrence from SIFMA Annex B Our takeaways from OCC analysis of 12 CFR Part 44
$184 million "recurring" cost Total $41.5 million "one-off" expense for top 46 banks
Policies & procedures +

- Collecting and filing metrics per year per bank = ~$2 million - Metrics: average cost for each of the top 7 = $2.53 million; the next 39 banks' average cost = $0.2 million
x 46 banks (to get on equal footing of OCC analysis) x 2 years of submission efforts - Policies & Procedures: average cost for each of the top 7 = $1.57 million, while next 39 banks' average cost = $0.126 million
Metrcis

- claims there are over 5 million data points in average submitted for each metrics filing Metrics are expected to be logical outcome of robust control systems, so it is a "one-off" automation cost rather than manually regurgitating data from
- Average 2500 pages of Volcker policies and prcedures multiple places.
* Policies and procedures are all good as long as they can be enforced. However, there seems to be trouble for If the cost is about risk data aggregation relates to BCBS-239 or other project, then it shouldn't be attributed to Volcker.
banks rigorously qualifying their trades for various Volcker exemptions based on comments submitted by the If these costs are all specified to directly relate to Volcker, then it's a major weakness that regulators shouldn't trust banks that they can efficiently and
industry effectively monitor compliance through metrics. Hence, it should revert back to a trade-by-trade scrutiny.
Unknown [Very Little] Total $512.9 million per annum
[- Shouldn't count any cost related to regurgitating Risk Appetite Statement (RAS) as RENTD because they are - Dedicated Full Time Employee (FTE) per desk to focus on RENTD: hourly rate $95.37 x 40 hrs/wk x 52 wk/year + 30% benefit = $257,875 all-in cost per desk x
RENTD

not the same 1100 trading desks from top 7 banks and 491 desks from the next 39 banks = $410.3 million/ annum
- OCC original analysis expects bank to devote 88-95% of Volcker compliane budget in RENTD, while the - RENTD Testing & Validation: $70.9 million for top 7 banks each year and $31.7 for the next 39 banks each year = $102.6 million
industry digress to other regulatory priorities] - The industry didn't put their compliance $ where it should be - ensure "reasonableness" of activities
compliance expenditures

Lower Bound: $402 million / Upper bound: $541 million

Approx $250 million traceable cost, excluding covered funds compliance cost
Sub-total of banks'

- that excludes Haircut (5.5%) on impermissible covered funds $3.63 billion and $165 million on additional capital
(assuming $184 million + 10,000 training hrs x $124/hr x 46 banks + $9.7million attestation)
- Per SIFMA, banks have have split business units into multiple trading desks to ensure that they do not rely on multiple exclusions or exemptions, resulting in
- Average over 10,000 training hours each year per bank (training an army of intruders to invite daily trading
an average of 95 trading desks (as compared to OCC analysis: 1591 desks for top 46 banks = 34.6 desks). Fewer employed traders as result of prop trading
operations verus automated survelliance to red-flag suspicious trades)
desks shut down, yet the industry have more desks than before, that's puzzling!
- 1700 hours spent on CEO attestation (assuming same all-in hourly cost/ FTE $124 x 1700hrs x 46 banks = $9.7
- The industry devoted countless hours and resources in lobbying and compilation of documents. However, they haven't spend enough efforts to advance
million if that counts toward independent testing costs, that's still less than 10% of the RENTD Testing &
their methods to account for "reasonable" level of securities inventory and put in place a system of internal controls reasonably designed to "prevent" the
Validation cost that the OCC has expected)
occurrence of activities or investments prohibited by the regulations.

$3.63 billion + $0.69 billion* = $4.32 billion

[Myth, but it's going to be much more than Prop Trading Ban
- Assumpting 5.5% haircut on fire-sale/ divestment of ~$66 billion impermissible covered funds
- Divest of covered funds is a direct hit to affect many affiliates and partners of banks
Covered Funds

- that excludes compliance cost to ensure risks from covered funds/ affiliates won't come back to haunt banks (Super 23A)
- Banks lobbying hard in conjunction with stakeholders to seek exclusions/ modifications
* Per SIA.org, combined the costs for external resources (outside counsel) to complement the work of internal teams in organizing and performing the
- Covered funds requirements are relatively more "prescriptive" than prop trading ban, and there are concrete
covered funds review process can easily added up to $15 million or more for the majority of major banks. Multiple $15 million by 46 top banks = $690 million
works to be done, but the works are highly manual]
- OCC believe the rule a "major rule" under the Continuing Resolution Authority (CRA), and already disclaimed that their estimate does not capture indirect
- SIFMA worked with Bloomberg and KPMG to analyze > 1 million covered fund vehichles, half million of
costs due to decrease market liquidity and the impact this decrease in liquidity may have on the market value of some assets and the cost to corporations of
CUSIPs issued by common types of securitizations, and more
issuing debt. So, one should expect these direct and indirect costs are all "factored" in.

10 Billion [No, it doesn't reconcile with the current market realities] $4.3 Billion [A better estimate than the industry, but still hasn't reached that amount yet]
- Bernstein Research estimate that Volcker Rule could cost banks $10 billion a year in pre-tax earnings, - OCC estimate total direct annual costs (prop trade + covered funds) associated with the final rule.
TOTAL

including reduce of non-exempt fixed income revenue by 20-25%. The prohibition of flow trading would impact - The industry has to accept a new normal in the market (i.e. primary dealers' inventory of corporate debt securities likely won't return to the peak of $285
55% of total revenue, and with such a revenue decline, the industry FICC pre-tax margin would decline from billion in 2007)
24% to an estimated 17% ... - Banks have paid out $100 Billion in U.S. fines (from 2009-March 2014), Volcker compliance cost is merely a tiny fraction of that.

This addendum should be read in conjunction with the open letter submitted to the OCC regarding Volcker Revision, see http://www.databoiler.com/index_htm_files/DataBoiler%20Volcker619%20Comments.pdf Page 4 of 4