For those anxiously awaiting the oft-promised FAQ on metrics from the interagency task force on Volcker, the OCC has provided the answer. In a Dear CEO letter dated yesterday, the OCC makes it clear in the following guidance that Volcker Rule metrics recording, as many of us have been saying for some time, begins on July 1st. The relevant text of the Dear CEO letter is below. Who knew that Dear CEO letters are the new FAQs?
“Banks with trading assets and liabilities of at least $50 billion will be required to report metrics designed to monitor their permitted trading activities. These banks must
- begin to measure and record the required metrics on a daily basis starting July 1, 2014, and report their daily metrics recorded during the month of July to the OCC by September 2, 2014.
- continue to report metrics data for each calendar month within 30 days of month-end through 2014, unless the OCC notifies them in writing that they must report on a different basis.
- beginning with information for the month of January 2015, report metrics within 10 days of the end of each calendar month, unless the OCC notifies the banks in writing that they must report on a different basis.”
OCC Bulletin 2014-9 (Mar. 25, 2014) available here: http://www.occ.treas.gov/news-issuances/bulletins/2014/bulletin-2014-9.html