Volcker Rule - Comment Letter - HSBC Bank USA - February 13, 2012

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Volcker Rule
February 13, 2012

HSBC “urges the Agencies to reconsider the extraterritorial reach of the Proposed Rule by making the following changes:

  • expanding the ‘solely outside the United States’ exemption so that proprietary trading activities of non-U.S. banks that do not result in additional risk being added to the U.S. financial system fall outside the scope of the Volcker Rule
  • extending the exemption for proprietary trading in U.S. government obligations to cover non-U.S. government obligations, state and municipal agency obligations and derivatives on each of these categories of securities
  • broadening the scope of the Proposed Rule’s exemptions for market making, risk-mitigating hedging, customer facilitation and other permitted activities”

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