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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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The U.S. Federal Reserve issued the results of the third round of stress tests since 2009. It said 18 0f 19 financial firms had enough capital buffers to continue lending in a sharp decline in the economy with a fall in housing prices and the stock market and unemployment rising to 13%. Ally Financial failed the test. Citigroup, MetLife and SunTrust Banks were asked to resubmit their capital plans to the Fed. Citigroup's dividend plan was rejected. No banks were asked to raise capital. J.P. Morgan and other banks were allowed to issue dividends and buyback shares. J.P. Morgan plans to repurchase $15 billion in stocks in the next 12 months. Wells Fargo and U.S. Bancorp also plan to issue dividends and buyback shares. Analyst estimates are for $32 billion in added dividend increases and share buybacks in in the next 12 months. The results are a boost for bank stocks.

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S&P's faulty ratings on U.S. mortgage securities was a critical factor leading to the financial crisis of 2008-2009, and the deep recession that followed in the U.S. Recovery was only made possible by large government stimulus and central bank intervention with monetary easing on a massive scale. The effects are still evident after millions of people lost their homes in foreclosures and widening income inequality. Yet it took about 7 years before S&P accepted responsibility and settled with the Justice Department. Earlier S&P accused the Justice Department of suing the company in retaliation for a downgrade of U.S. government debt in 2011. In the convoluted upside down nature of such lawsuits and protests by defendents, McGraw Hill said that the settlement "contains no findings of violations of law." Yet the government produced 290 million documents in response to discovery requested by S&P. Associate U.S. Attorney General, Stuart Delery, the top negotiator for the government, says "put simply, the department brought this case because S&P committed fraud." Delery says no case in Justice Department history has produced this many documents. The Justice Department cited several instances of breach of duty in a statement signed by both parties. In 2007 an internal group's downgrade recommendation for a large number of mortgage securities was rejected by upper management because of concern S&P would lose business. In another cited instance S&P alters its ratings model for grading complex risky securities in 2004 with the goal of being able to issue grades for "2-3 notch improvements" and resulting "improving of S&P market share." S&P had about $1.9 billion in cash balances in third quarter 2014, say analysts, and the settlement was designed to set the right course but not hurt S&P in carrying out its role of issuing about 95% of ratings globally along with counterparts Moody's and Fitch. Mississippi Attorney General Jim Hood says S&P's responsibility lies in that banks might be expected to do something shady, but credit ratings agencies were the ones the country looked up to to do the right thing and flag this....

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Efforts by banks to bring their operations in line with regulator requirements. The Citigroup bank much smaller than at the time of the financial crisis, with its "living will" approved by the U.S. Federal Reserve in April 2016.

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Paul Barrett, Assistant Managing Editor of Business Week says the year 2009 will represent a year of lost opportunity to reform the financial system. The Obama administration and Congress did not have the courage to do what is needed, and did not take Paul Volcker's advice on the danger of ahandful of banking institutions controllig a major portion of global banking assets. The WSJ reported that the world's 10 biggest banks account for about 70% of global banking assets, up from 59% before the crisis. It is ayear he says of missed opportunities and little was done in so many areas, including derivatives regulation and the credit rating agencies continue doing business as before with clear conflict of interest inherent in their practices. Barrett says genuine reform fizzled, and we will regret it. The Obama administration and Congress let themselves be influenced by the banking lobbyists and bankers, just as they allowed genuine health reform opportunities to slip in 2009.

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The Justice Department, the Securities and Exchange Commission and the Federal Bureau of Investigation respond to inquiries by the New York Times on how adequately their agencies have responded to the financial crisis of 2008. The inquiries relate to whether these agencies have conducted the prosecutions of senior executives of financial companies that are necessary to ensure there is no recurrence of the behaviours in financial markets that led to the crisis.

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Proposals from the Vickers Commission on banking reforms in the UK that could be adopted in the U.S. to reduce systemic risks from proprietary trading.

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Barry Ritholtz lists the causes of the financial crisis, He says New York Mayor Bloomberg's exoneration of the financial industry is simply false- what he calls "the Big Lie"- even though Congress, regulators and the Greenspan Fed acted irresponsibly and created favorable conditions for the actions of the financial industry.

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The U.S. Fed publishes a 38 page policy statement in Nov. 2013 on procedures and guidelines for stress tests of U.S. banks. Efforts to increase clarity for stress tests. Outlines for three scenarios- baseline, adverse and severely adverse.

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A behind the scenes account of what happened at JP Morgan Chase after CEO Jamie Dimon discovered the trading losses of the London Whale through the pages of the Wall Street Journal, on April 6, 2012.

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U.S. District Judge Jed Rakoff was critical of the S.E.C.'s practice of entering into consent judgements which allowed defendents to not admit to wrongdoing. In his order Judge Rakoff rejected a $285 million settlement with Citigroup for a mortgage-bond deal. In his order he said such settlements are viewed by the business community as "a cost of doing business." He found it hard to discern what the S.E.C. would be getting out of such a settlement "except a quick headline." Rakoff summarized the problem with such settlements and the S.E.C.'s practices when it comes to the public's interest: "In any case like this that touches on the transparency of financial markets whose gyrations have so depressed our economy and debilitated our lives, there is an overriding public interest in knowing the truth. In much of the world, propaganda reigns, and truth is confined to secretive, fearful whispers. Even in our nation, apologists for suppressing or obscuring the truth can always be found. But the S.E.C., of all agencies, has a duty, inherent in its statutory mission, to see that the truth emerges; and if it fails to do so, this Court must not, in the name of deference or convenience, grant judicial enforcement to the agency's contrivances."...

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The lack of prosecutions after the financial crisis of 2008. Several reasons cited- the fragility of the financial system in 2009, the lack of support from regulatory agencies, the lack of funding for the FBI and the Justice Department to assign special resources for the effort. Even the most egregious cases such as the one at Countrywide have not been prosecuted, even from the standpoint of preventing the recurrence of such behaviours.