July 22, 2014
"Pre-Volcker, the term trading desk tended to be used in a very granular way by institutions – a large bank holding company might have stated it has hundreds if not a thousand trading desks globally in its internal corporate governance reporting. Under Volcker, that would be a very bad number for a variety of reasons, not least of which is the fact that each of those desks generates separate reporting and compliance requirements. Under the Volcker rule, a bank no longer states that it has a thousand trading desks but rather only 80 or so. Those 80 desks might encompass multiple people sitting in multiple locations, covering multiple trading books on behalf of several affiliated entities, but they are all part of one overall trading desk. A bank would have to demonstrate that its determination of its trading desks is consistent with the Volcker rule – that it has standalone governance, trading limits, compliance and monitoring for each trading desk. Of course, being too aggressive could raise regulatory flags, and could be seen as potentially masking proprietary positions."
— Scott Cammarn comments in Risk Magazine about how banks are interpreting the Volcker rule’s definition of a trading desk.