The hardware and software for all six systems is easily available, but they vary considerably in proprietary components, installation requirements and customisability.
Since this is likely to vary from product to product, it is not possible to outline the requirements of proprietary cleaning products here.
Existing automated compliance checking (ACC) systems are limited in their automation; they rely on the use of hard-coded, proprietary rules for representing regulatory requirements, which requires major manual effort in extracting regulatory information from textual regulatory documents and coding these information into a rule format.
And these devilish details -- capital requirement levels, proprietary trading restrictions, the independence of the proposed consumer financial protection agency, etc., etc. -- are critical.
"The reader should review the exact language of the proprietary lease to determine its requirements," he said.
Specifically, the bill advocates: (i) charging the firms premiums for systemic risk; (ii) imposing higher capital and liquidity requirements; (iii) restricting proprietary trading activities if deemed necessary to limit risk; and (iv) forcing the issuance of contingent capital, which will bring back market discipline and shift some of the risk from taxpayers back to creditors.
"Generally, there is no requirement that the co-op use the same material that was previously used," Mr. Saft said, adding that even if the letter writer's proprietary lease contained such a requirement, it would be inapplicable to the present situation because the earlier shareholder replaced the standard flooring.
Under the proposals, banks that are deemed systemically important would face restrictions in the form of "strict" capital requirements—on high-risk proprietary activities, that is bets made using their own money.
Proprietary software options with different hardware requirements were available but rejected because recurring licensing costs could not be sustained and hardware was a 1-time expense.
