In order to minimize burden and give full effect to the conformance period provisions of section 619, the reporting requirements are applied in a graduated manner, with only the firms with the largest trading books required to report metrics.
These metrics will be used to trigger further scrutiny by banking entities and examiners in their evaluation of whether a banking entity is engaged in permitted or prohibited trading activities. As part of implementation, we expect that a horizontal comparison of these metrics across firms and over appropriate time periods will help improve our understanding of the trading activities of banking entities.