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That former Fed chairman Volcker considered CEO attestation a critical part of the Volcker Rule is reflected in his advice about its implementation- to keep broad and let the responsibility for seeing that the proper activity takes place on bank management. CEO attestation is now part of the final form of the Volcker Rule requiring CEO's to sign off that the financial firm is in compliance. It may lead to a sequence of attestations or sub-certifications from business heads to upper management in actual practice, says Joseph Grundfest at Stanford University. The Financial Stability Oversight Council, created under the Dodd-Frank legislation, proposed this requirement saying that the rule require" public attestation by the CEO that compliance standards are continually being met." The WSJ points out that 5 of the FSOC's members are also top officials at government agencies writing the Volcker Rule. Jacob Lew, Treasury Secretary, leads the council. Lew says about the individual accountability of the top executive- "it puts in place strong compliance requirements that require those in charge of financial institutions to make sure that the 'tone at the top' sends the right signals to the whole firm."