Sia Partners – Volcker Credentials US Regional Bank Context
Sia Partners approach
• On December 10, 2013, U.S. Regulators released the Final Volcker Rule
• Strong cooperation with Legal, Compliance, Business, Risk and
• The bank and all of its subsidiaries are subject to the following provisions of the Volcker
Rule: • A ban on proprietary trading activities, • Restrictions in investments and sponsorship of certain private equity funds and
hedge funds, that fall under the definition of “covered funds”, • A requirement to establish a compliance program, including enhanced compliance obligations and reporting of trading metrics. • In this context, the bank has asked Sia Partners to assist in the development of a compliance program to comply with the Volcker Rule.
Objectives • Review the initial assessment of trading and investment activities that are impacted by
the restrictions of the Rule, and assist in getting validation of this assessment from Senior Management
Operations, • Collective sessions with stakeholders to review and validate
initial assessment of the activities impacted by the Rule, • Interviews and dedicated workshops to collect information
about the current situation (compliance framework; existing policies, procedures and controls; Risk and P&L indicators; existing systems), • In-depth analysis of the requirements of the Rule, • Organization of various project work streams (“Gap Analysis & Roadmap” and “Metrics Reporting”) In order to produce the following deliverables: • Impact assessment • Compliance framework gap analysis and roadmap • Trading metrics business requirements
• Produce a gap analysis between the existing compliance framework at the bank and the
enhanced compliance obligations required by the Rule, and deliver an implementation roadmap: • Determine a list of required Policies and Procedures • Inventory existing Policies and Procedures & perform a gap analysis • Draw documentation plan • Determine limits and controls • Establish Management Framework • Define training approach • Define testing strategy • Determine record retention requirements • Determine roles & responsibilities around metrics production • Write trading metrics reporting business requirements: • Define calculation assumptions for the 7 metrics required by the Volcker Rule • Write business requirements accordingly, in order to specify to IT the
Key points • Interpretation of long and complex requirements and
clarification so as to facilitate Management decision-making and operational implementation • Quick integration of Sia Partners consultants within the bank • Intervention in San Francisco
Sia Partners added value • Regulatory and business knowledge of capital market and retail
banking activities • Dedicated working group within Sia Partners to monitor /
decrypt regulatory issues (Volcker, Dodd Frank Title VII, etc.) • Proven methodological skills in matters of project management
requirements that need to be developed and implemented
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