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The Volcker Rule goes into effect in July 2012. Under the rule proprietary trading operations of banks must be divested by 2012, with banks getting an additional three years to comply for specific situations. The financial industry is pushing back against the rule with comment letters from industry firms. Mr. Volcker outlined his response in his letter of comments to the objections raised by financial firms. To the objection that this would reduce liquidity in the market and raise corporate borrowing rates, Vocker says that too much liquidity is a problem because firms tend to bid up asset prices in the hope that they can always find buyers.

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Comments by the banking sector and the central bank of Canada on the Volcker Rule.

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In comments to the Financial Inquiry Commission bankers Blankfein and Dimon show a lack of comprehension of the magnitude of the global financial crisis and their role in it. Blankfein says this kind of crisis was a once in a 100 years event and one should't react. Dimon says such crises happen every 5 to 7 years and is not something to get overly concerned about. And they offer no solutions or problem solving ideas, except to resist any form of regulation that would strictlly limit damage from a future crisis.

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Eisinger says the Volcker Rule is voluminous and complex with 530 pages, because banks and lobbyists with complicit regulators wanted it that way. This is also what Volcker told Charlie Rose in an interview, that banks can't complain that it is complex and at the same time work to add complex language to the rule.

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This editorial lists the essential points that the Volcker Rule- as it is written by U.S. regulators -must include to ensure the safety of the American financial system. These points cover limiting speculation, putting in place clearly defined and strong penalties, and addressing loopholes.

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Questions raised about whether the bets made by trader Iksil of the CIO at JP Morgan Chase were made to hedge risk, or to simply engage in proprietary trading for the bank in the hope of making large speculative profits. Bets made earlier by Iksil made large profits, but were simply speculative trades that increased bank profits. In late 2011 Iksil made a $1 billion bet that some companies would default on their debt in a few months. When American Airlines filed for bankruptcy protection Iksil's trades made about $450 million for Chase. But the trade had little to do with hedging risk.

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Turkey's lira depreciates by 21% in 2013 and an additional 7% by January 24, 2014. The central bank uses up a third of its foreign exchange reserves or $19 billion in intervention to support the lira since June 2013. The intervention on June 24, 2014, did not work and the lira continued its downward slide to 2.30 to the lira. The political protests in Turkey and divisions within factions in the government about corruption probes has led to a political crisis and investors pulling back from Turkey. The central bank failed to increase interest rates as expected by investors and suggested by the IMF. Inflation is running at 7.4% for 2013. In August 2001 a currency crisis caused the banking system to collapse. The financial position is stronger than in that crisis, yet the recent political crisis and the large current account deficit has badly dented investor sentiment.

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Robert Doll, equity strategist for Black Rock, the world's largest money manager, says the growing population of the U.S. will drive economic growth in the next decade compared to Japan and Europe. He says that over the next two decades the U.S. work force will grow by 11%, Europe's will decline by 5%, and Japan's will decline by 17%. China's population growth will be only slightly more than that of the U.S. during that period and Doll expects China's growth to slow. He sees America as the best bet in a bad neighborhood. Higher immigration in the U.S. is a huge positive, as he points out economic growth is simply the product of the change in the size of the work force multiplied by its productivity. And America's productivity is good enough compared to other nations, is how Doll sees it. In 1995 the U.S. produced 25% of the world's goods and services, it was still 25% in 2010 says Doll. Other economists have pointed to this and observed a similiar pattern for most of the twentieth century. Doll sees this pattern continuing. India's population will show signficant growth and he sees greater opportunity there for long term investing. Doll sees a decoupling between U.S. stock markets and high unemployment. Most of the large U.S. companies generate a large portion of their sales and profits overseas. He estimates 40% of the business of these companies is overseas. Doll's estimate is for 70% of the incremental earnings growth of the S&P 500 companies coming from overseas markets. He also expects higher inflation with the Fed keeping it from getting out of control, and deficit cutting efforts to cut some trillions over the years. He sees favorable prospects for equities based on the money growth being strong and credit markets being good....

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Gongloff points out that the word exemption occurs on 100 of the 200 pages of the final draft of the Volcker Rule published for comments in September 2011, for a total of 426 times. The banks have 2 years after its introduction in July 2012 to comply with its provisions and are allowed to petition the board for 3 one year extensions taking the process to July 2014 or July 2017. And this whole exercizes resembles some form of kabuki theater as the title of this piece suggests, and makes going through its detail meaningless. Especially since the probability of a new administration in 2014 or in 2017 are high. At that time new rules would be written.

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Before taking up the job of enforcement chief at the SEC, Robert Khuzami spent five years running the U.S. legal division of Deutsche Bank. In that job he worked with lawyers who advised on the collaterized debt obligations issued by the bank, and the details to be disclosed to investors. Like Goldman, Deutsche Bank has faced alllegations of not disclosing the proper information for its CDO's. Before joining Deutsche Bank, Khuzami was a prosecutor in the U.S. attorney's office in Manhattan for 11 years.

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Wessel summarizes the existing thinking of the administration and its critics on ways to prevent the next banking crisis. The Shultz-Mervyn King School which says breakup the largest banks into smaller banks so they are not too big to fail. The Volcker school which says separate utility banking from thre risk taking banking of the trading desks of investment banks. And the Geithner-Frank school of avoiding these tough choices in the face of intense lobbying by the banks by glossing over the problem, their latest proposal suggesting that Treasury collect the bill of abank bailout from the remaining weakened banks in afinancial crisis of the future. But the Geithner -Frank solution still has Treasury, meaning the government footing the bill, as collecting the bailout from remaining banks that are weak in such a financial crisis may not be feasible. and it would further worsen the government's finances, raising questions about these proposals which may amount to doing a little better than nothing. In effect avoiding the tough choices of breaking up the larger banks or separating utility banking from trading desks of investment banks....

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Beatrice Weder di Mauro of the German Council of Economic Experts points to the needs for beeter incentives for regulators to ensure their is no local regulatory capture and to ensure that regulators are doing their job well. One is to increase the pay of central bankers and bank supervisors and to make the job nearly as attractive as working in the private sector. The other is to give more authority to supranational institutions to regulate. She points out that competition has been kept in the Eu's domain and this has helped ensure consistency in the way bank bail outs are being handled in the European countries. The same needs to happen in Europe for banking reguolation and oversight. She points out the flaw in the argument for national regulators on the basis that the money to bailouts comes locally. a substantial part of the bailouts come in the form of regulatory forbearance, enabling banks to make higher profits because of reduced competition, and implicit support from central banks. And she adds that the temptation to solve the future crises by these "off balance sheet methods" is greater now because no one wants to go to parliament or congress to get bail out money for banking instituitons....

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The business model where hedge funds take in short term money from investors for a 2% fee and a fifth of profits, and invest it in longer term bets and sometimes illiquid situations, is breaking down. This happened to the investment banks and ended with the collapse of Lehman and Bear Stearns. With losses approaching 20%, many illiquid investments, and investors asking for their money, this model may lead to a rapid shrinking of the hedge fund industry, which now has about $2 trillion of investor money.

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Another significant development in this crisis, is how small businesses got addicted to credit card debt as a way to operate for ongoing expenses of the small business, from a small nursery, to abed and breakfast or a solo law practice. There are an estimated 27.2 million small businesses who are supposed to be one of the growth engines of the economy. Credit card debt when banks are tightening up credit and businesses are unable to meet expenses, is extremely costly because of the underlying usurious nature of the industry in the US and lax regulation. It will only push more businesses, that have acquired the bad habit of credit cards to finance operations, into bankruptcy. There were 5 million business credit cards in 2000. By 2009 after Visa Inc, American Express Co, and MasterCard Inc. and Discover Financial Services Inc. pushed these cards aggressively, using a new credit scoring system that looked less at the business and more at personal credit scores, the number jumped six fold to what Nilsen Reports estimates as 29 million business credit cards. The spending on these cards jumped for this period four fold, from $70 billion to $296 billion. As the average debt on each credit card jumped so did the likelihood of some of these card holders difficulties. Missed payments could lead to interest rates for some card holders jumping to 30+% from initial rates of 7-8%, all in the last 12 months. This makes small businesses less likely to create the jobs they created in the past, and one more troublespot in this economy....

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Ann Lee a former investment banker and now adjunct Professor at New York University, gives us facts that show the smaller banks that lend to small and medium sized businesses in the country are being closed by the FDIC. According to ADP small business that employs between 1 to 49 people, accounts for 48 million jobs, those between 50 and 499 employees account for 42 million jobs, and large business for only 17 million jobs. Without access to capital these small and medium sized businesses will continue to layoff employees, creating a vicious cycle of falling credit and demand. According to Automatic Data Processing's August employment report large business shed 60,000 jobs, medium sized business 116,000 jobs and small businesses shed 122,000 jobs. These smaller banks says Lee have done most of the lending to small and medium sized businesses. And overall lending has dropped from pre-crisis levels. Treasury's Capital Purchase Monthly Lending Report shows that banks that received government money actually reduced loan balance by $54 billion. According to reports issued by major credit rating agencies $700 billion of asset backed securities were underwitten in 2007. In 2009 only $10 billion was issued. This has a significant impact in every area. Banks have no incentive to lend with all the bad nonperforming loans on their books. They only hope that over time renegotiated loan terms would enable to recover these loans. But this might take a decade says Lee, if this is similiar to other crises like the one in Japan. She says what the banks do to make money is to borrow virtually unlimited amounts from the Fed at near zero rates and earn money from the spread when they lend to the Treasury. Does our current banking system make sense she asks. Banks are not investing in economic activity, in real products and services,but engaged in agovernment backed shell game that enriches bankers at the expense of everyone else. She says that the banking lobby may prevail in preventing the nationalization of the banking system, but this will not prevent questions about the status quo and its assumptions from arising if the recovery and regulatory reforms fail. ...

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John Taylor on the dangers of a loose U.S. monetary policy and the effects this had in fueling a housing bubble in Spain, Ireland and other EU countries. Taylor points to the bubble ocurring in emerging market economies from low interest rates. Taylor says the ECB's interest rate moves in 2003-2005 were affected by the Fed's low interest rates. He estimates the ECB set rates about two percentage points too low leading to housing bubbles in EU countries. A similiar process is taking place today with the Fed's near zero interest rate policy. Taylor points to interest rates in a group of 18 emerging market economies- including Brazil, China, India, Mexico and Turkey, which have held interest rates on average about 5 percentage points below widely used benchmarks fueling a doubling of global commodity prices between 2009-2011. The U.S. Fed's policies make it harder for central banks in emerging market economies to take aggresssive action against bubbles developing in these countries. Taylor says his does not mean that the Fed should not pay attention to the U.S. unemployment rate and long term unemployed, but should keep in mind the negative effects of slowing demand in emerging market economies and in the EU as a result of its monetary policy of keeping rates at near zero for long periods of time. This feeds back to the U.S. economy at a critical time....