Dear Suitors;
This is the kind of impact that I find encouraging. But first I want to touch on some principles that I think apply. Communication is synonymous with creation and only beings of like order can truly communicate.
I refused for cause
the final rule just recently. It was as though the OCC planted the $50B Stress Testing (attached) just prior the final rule Notice so that I might forego the R4C on the final rule, and it almost worked. I was thinking, Hell I just refused for cause the Stress Testing; that should cover this final rule Notice too. But I decided to R4C and as the Holy Spirit would have it the process server was dawdling and I caught her just in time to get both done Monday a week ago (also attached). Today the OCC released
the newest comment about the final rule.
The purpose all along has been to mitigate the scope of effect of OCC and FDIC regulation and rule so that it has no adverse affect on my Bill of Exchange. The original scope of the new final rule was:
Summary
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) on August 30, 2012, published in the Federal Register a final rule that amends their respective market risk capital rules, which generally apply to banking organizations that engage in substantial trading activity. The revisions broaden the scope of these rules to better capture the risks inherent in trading positions. Specifically, the final rule improves the sensitivity to risks...
Compare that with today?s release, again commenting on the scope in the first paragraph of the Summary:
Summary
The Office of the Comptroller of the Currency (OCC) advises federal savings associations to review the Federal Deposit Insurance Corporation?s (FDIC) final rule and guidance issued July 24, 2012, on investments in corporate debt securities. Federal savings associations have until January 1, 2013, to comply with the FDIC?s final rule. In addition, the OCC reminds federal savings associations they must comply by January 1, 2013?
It can be read that todays notice only applies to federal savings associations, but over the years I have found that this means that the OCC and FDIC are withdrawing the broad scope of the final rule and admitting that they only had authority over their own all along. ? Except for if I were to acquiesce that the final rule generally applied to banking organizations that engage in substantial trading activity.
Regards,
David Merrill.