Such contagion would meaningfully change the risks for investors that currently hold Portuguese bonds given the increasing possibility that private sector creditor participation will be required as a prerequisite for any further finance”. 9  ]  Moody's noted that “European policymakers have grown increasingly concerned about the shifting of Greek debt held by private investors onto the balance sheets of the official sector.
However, banks that have structured their operations in these ways would be prohibited by the rules from taking advantage of the exception granted by the Congress, even though  4  BIS Review 70/2001  their relationships with customers are maintained in a trust or fiduciary department and regularly examined by bank examiners for compliance with fiduciary principles.