Proprietary trading

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The proprietary trading (including proprietary trading ; English Proprietary Trading ) is the banking of the trade with financial instruments ( cash , securities , foreign exchange , varieties , precious metals , loans or derivatives ) in order to achieve short-term in its own name and for its own account trading profits, which is not triggered by customer business .

General

Credit institutions can conduct banking business with non-banks and other credit institutions ( interbank trade ). In the customer business, the banks have an order from the customer (non-bank or bank) or can be expected later. In the case of proprietary trading, however, there is no customer order and cannot be expected later. In addition, the motive plays an important role in entering into the business, because proprietary trading is only carried out if short-term profit expectations are recognized and realized. For this purpose, financial instruments are held and / or taken over for resale in order to make short-term use of existing and / or expected differences between the purchase and sales price or other price or interest rate fluctuations. Join banks in the markets in its own name and on its own account, enlist market risk , the odds of winning includes, but even with the loss risks can threaten. In addition to credit risk and liquidity risk, market risk is a typical banking risk.

history

The linguist Kaspar von Stieler formulated as early as 1674 "Commissions are safer than doing your own actions ..." and thus pointed out the differences between proprietary trading and commission sales. For Jonas Ludwig von Heß , proprietary trading ( proper trading ) existed in 1811 if someone “buys goods in foreign ports and country towns on speculation and for his account ...”. In the German dictionary of 1840, it was understood to mean “purchasing goods for one's own account”.

The focus of the activities of the banks has always been the "execution of customer orders". The origins of the proprietary trading in its own name the commission agent in securities trading . The commission agent who actually mediates between buyer and seller acts as seller or buyer himself and delivers or acquires the securities for his own account. Here self-entry became a commercial practice because the emphasis was placed on the desired economic success, buying or selling. In 1858, a commission to deliberate on a new commercial code found self-advocacy as a particular law, which was even considered to be German customary law . Section 376 ADHGB , which has been in force since May 1861, restricted self-entry to goods or securities with a market or stock exchange price. The ADHGB thus sanctioned a mixture of proprietary trading and foreign trading. Arthur Nussbaum dealt extensively with commission and proprietary trading in 1917. In 1932 it was already common to speak of proprietary trading when the banker approaches his customer as a seller (and not an intermediary) in a securities purchase transaction. In the case of self-entry and proprietary trading, securities are purchased or sold - the hedging transaction - not for the account of the bank customer, but for the bank's own account.

The banks began increasingly from 1970 to establish proprietary trading as a profitable sector. Over the years, however, the earnings turned out to be extremely volatile and unsustainable, and the losses incurred even led to banking crises such as the one at the Herstatt Bank in June 1974 . The very positive development of the stock markets in particular led to a significant increase in the proprietary trading results of German credit institutions in 1999. Deutsche Bank was able to more than double its trading result in 1999, and proprietary trading represented a significant income item for the other major banks, the top public and cooperative institutions. In July 2010, the so-called “Volcker rule” in the USA provided a component of the Dodd – Frank Acts for restricting speculative banking that does not benefit customers. After that, the banks are only allowed to trade on their own if this is to protect their own risks.

Legal issues

Which transactions fall into proprietary trading under commercial law cannot be assessed on the basis of the type of transaction. Financial instruments such as securities, foreign exchange, sorts, precious metals or derivatives are by no means necessarily assigned to proprietary trading, but can also represent a service in customer business.

Banking regulatory law

According to banking supervisory law , banking transactions or financial services are differentiated in the KWG according to whose order and for whose account (risk) they are carried out:

  • Trading in the name of a third party for the account of a third party (open representation): is a contract brokerage ( section 1 (1a) sentence 2 no. 2 KWG). This includes the financial service of placing an issue in open representation.
  • Trading in one's own name for the account of third parties (hidden representation): is finance commission business (Section 1 (1) sentence 2 no. 4 KWG). This includes the purchase and sale of financial instruments on a commission basis within the meaning of Section 1 (11) KWG as banking business.
  • Trading in your own name for your own account : Section 1 (1a) sentence 2 no. 4 KWG is proprietary trading as a banking business, provided it is to be understood as a “service for others”. The “service for others” is characterized by the fact that the proprietary trader acts in response to a customer order or in anticipation of such, because he has better access to the market in which he operates in order to cover himself for customer business to close the position resulting from the customer business or to give the customer market access at all, which would otherwise remain closed to him. These include banks, which enable private investors to buy securities in the first place through fixed-price transactions, as well as abandonment transactions with which the stockbroker compensates for temporary imbalances between supply and demand in less liquid values. If trading in financial instruments falls outside the scope of proprietary trading within the meaning of section 1 (1a) sentence 2 no. 4 of the KWG due to the lack of a service character, it must be assigned to proprietary trading (section 1 (1a) sentence 3 KWG).
  • There are no customer orders for the proprietary business faked as proprietary trading by section 1 (1a) sentence 3 KWG and will not be received later. The proprietary business ( nostro trading ) is pursued solely in one's own interest and without a customer order. This includes all acquisitions and sales of financial instruments for own account that are not recorded as a service. A service character is absent, for example, if the business is carried out without a corresponding customer order and no other commercial reference can be recognized for a potential customer. All transactions based on customer orders and carried out on behalf of a third party are never classified as proprietary trading. The regulatory term "proprietary business" thus corresponds to proprietary trading in the banking sense.

"Trading for someone else" is therefore conceivable in three variants:

  1. By way of open representation (in the name of a third party for the account of a third party - Section 1 (1a) sentence 2 no.2 KWG),
  2. by way of covert representation (in one's own name for the account of a third party - Section 1 Paragraph 1 Sentence 2 No. 4 KWG) and
  3. by way of proprietary trading for someone else (in your own name for your own account - section 1 (1a) sentence 2 no. 4 KWG).

Proprietary trading differs from the first two alternatives in that there are regularly two purchase contracts: The financial service provider acquires a financial instrument in his own name and then sells it on to the customer. The prerequisite for proprietary trading is therefore that a specific customer order to purchase a specific security - usually at an agreed fixed price - has been placed before the purchase.

In October 2014, BaFin took the not always easy delimitation as an opportunity to comment on the facts of proprietary trading and proprietary business. According to this, the offense of proprietary trading according to section 1 (1a) sentence 2 no.4 KWG covers four variants:

  • the continuous offering of the purchase or sale of financial instruments on an organized market or in a multilateral trading system at self-set prices (section 1 (1a) sentence 2 no.4a KWG),
  • frequent, organized and systematic trading for own account outside an organized market or a multilateral trading system by offering a system accessible to third parties in order to conduct business with them (section 1 (1a) sentence 2 no.4b KWG),
  • the acquisition or sale of financial instruments for one's own account as a service for others (section 1 (1a) sentence 2 no. 4c KWG) or
  • Buying or selling financial instruments for one's own account as a direct or indirect participant in a domestic organized market or multilateral trading system using a high-frequency algorithmic trading technique. This is characterized by the use of infrastructures that aim to minimize latency times, by the decision of the system about the initiation, generation, forwarding or execution of an order without human intervention for individual transactions or orders and by a high volume of messages during the day in the form of orders, quotes or cancellations , even without providing services to others (section 1 (1a) sentence 2 no. 4d KWG).

According to BaFin, the offense of proprietary business pursuant to section 1 (1a) sentence 3 KWG includes the acquisition and sale of financial instruments for your own account that is not proprietary trading within the meaning of section 1 (1a) sentence 2 no. 4 KWG. This means that all acquisitions and sales of financial instruments for one's own account are fully recorded either as a service that requires authorization in the form of proprietary trading or as an investment activity that also requires authorization in the form of proprietary trading. The element "for own account" serves to distinguish proprietary trading from finance commission business. While the acquisition and sale of financial instruments in the finance commission business (Section 1 (1) Sentence 2 No. 4 KWG) takes place for “third-party account”, the acquisition and sale in proprietary trading is done “for one's own account”; the credit institution bears the full price and performance risk.

Securities law

In the Securities Trading Act (WpHG), proprietary trading is defined differently under securities law. Here it is always “service for others” ( section 2 (8) no. 2 letter c WpHG) or as proprietary business “no service for others” (section 2 (8) sentence 6 WpHG). A bank is generally not obliged to inform its customers that it is selling third-party investment products by way of proprietary or proprietary trading at a price above its purchase price. Anyone who frequently and regularly conducts proprietary trading outside of organized markets and multilateral trading systems in an organized and systematic manner and thus assumes their own market risk is considered a systematic internaliser according to Section 2 (8) No. 2 (b) and Section 79 of the WpHG . He must comply with the obligations of Title III of Regulation (EU) No. 600/2014 (e.g. pre-trade transparency). These rules for internalisers are originally based on Article 21 of Regulation (EC) No. 1287/2006 of 10 August 2006.

According to § 31 DepotG, the provisions of §§ 18 to 30 DepotG applicable to commission agents also apply in the case of self-entry and proprietary trading. This equation of self-entry and proprietary trading with the agency commission is intended to protect bank customers. Self-entry consists in the fact that, according to Section 400 (1) of the German Commercial Code, the commission agent may buy or sell securities by delivering the securities himself as a buyer or as a seller.

Significance for banking operations

Proprietary trading is an important area of investment banking and is also a basic requirement for so-called market making . In addition to the lending business , proprietary trading in securities, derivatives and other market price-related financial market products is an important business area for banks operating across the region. In most cases , it was not possible to create new personnel or material capacities ( dealers , retail technology ), as these were already available for customer business. Proprietary trading can therefore contribute to the fact that the personnel and material trading capacities in banks are used to a greater extent in order to better cover the high fixed costs in these areas . By using its own funds, the bank becomes active in the money and capital markets and conducts business with financial instruments in its own name and for its own account.

Due to falling profits in customer business, banks increasingly operated proprietary trading, which initially brought in considerable profits . This was also the case with the Herstatt Bank , which collapsed in 1974 and which began trading on its own account in large volumes from 1971 onwards. For the balance sheet date December 31, 1973, it posted in fiscal year 1973 with an operating loss of 14 million DM, by the profits from proprietary trading of 48 million DM to a net income was transformed by 34 million DM. There was an open net position from forward exchange transactions of 711 million DM, 23 times the liable equity .

According to estimates by the Bundesbank, between 80 and 90% of the daily foreign exchange trading volume is accounted for by proprietary trading.

activities

Operational proprietary trading activities are the buying or selling of securities, currencies, types, precious metals, loans or derivatives, or the raising or investment of money. This can be done tactically through arbitrage or speculation , with the available strategies of building up open positions or closing , hedging or covering open positions in trading or banking books. Proprietary trading includes both short-term trading transactions and long-term, strategic positions. The price management is a part of proprietary trading, even if it was contractually agreed with the issuers of securities.

Risks

Risks arise in proprietary trading through the market risk , which consists of the individual risks of currency , interest rate , securities and commodity risks ( precious metal price risk ). They can occur individually or cumulatively. Compared with the risks from the banking book , especially the default risks on loans , the market price risks of proprietary trading were of secondary importance for a long time. At a typical large bank , around 4% of the equity capital required for regulatory purposes in 2004 was used to back market price risks in proprietary trading. In the 2004 financial year, the German credit institutions achieved the weakest proprietary trading result since 1994, which was mainly due to the big banks. In the 2008 financial year, the banks had to post drastic losses in proprietary trading. The net results from proprietary trading were dramatically affected by the financial crisis from 2007 ; the losses reached an all-time high in relation to the period 1993 to 2008. The main reasons for the drastic deterioration in the proprietary trading result were, in particular, high write-downs on structured finance (especially asset-backed securities (ABS), residential and commercial mortgage-backed securities (RMBS, CMBS) and Collateralized Debt Obligations (CDO) and large losses in the derivatives business. Among other things, this reflected the insolvency of the investment bank Lehman Brothers and, to a lesser extent, write-downs on specific foreign commitments as well as impairments in connection with monoline insurers. The major banks accounted for 82% of the proprietary trading losses of EUR 18.8 billion in 2008; Proprietary trading played practically no role in the earnings situation of the other groups of banks in 2008 either. In September 2004 this prompted Commerzbank to be the first major bank to stop proprietary trading.

In order to limit the risks from proprietary trading, the EU-wide capital adequacy regulation stipulates in Art. 317 ff. A link between open book positions (inventory risks) and the own funds of a credit institution. If the total open positions (according to one of the two alternatives) exceed 2% of own funds, these open positions are to be weighted with 8%. This automatically limits the volume of the risk-intensive open positions in proprietary trading.

Risk management

The risks in proprietary trading consist primarily of market and liquidity risks. From the banks' point of view, market risks arise from unexpected, negative developments in interest rates, exchange rates and other prices. The counterparty risk, which is caused by changing credit spreads, must also be taken into account here. Other dangers that should not be underestimated are operational risks (such as the failure of data processing systems) and legal risks (such as unforeseeable changes in the legal situation). The extent of market risk is measured using value-at-risk . The value-at-risk of a trading book is the upper loss limit which, with a given holding period, will not be exceeded with a high degree of probability (e.g. 99%). Global proprietary trading, especially with multiple inventory and sequential trading, requires a dynamic risk management process with continuous monitoring and management of the risks taken, taking into account the decentralized organization.

organization

The MaRisk generally see an organizational separation between the market area and the back office before to personal conflicts of interest should be avoided. In addition, dedicated written work instructions are stipulated, which are intended to ensure a uniform and risk-conscious organization of proprietary trading within the institute. In order to limit the bank-related proprietary trading risks, trader limits are specified, which consist of the following sub-limits:

  • Overnight limit is the limit on the open position at the end of the working day. It corresponds to the position limit, i.e. the risk limit for the individual trader. Depending on how the market risk is measured, the calculation of the risk per trader can be determined using a scenario analysis (e.g. 1% change in interest rates, 4% change in currency) or using more complicated procedures (such as the value at risk approach).
  • Intraday limit / daylight limit is the permission to temporarily build up an open position during the working day. This intraday limit is determined depending on the qualification and position of the trader and the market liquidity in the traded instrument. The limit can also depend on whether or not a bank has a market maker function in this instrument.
  • Quotation limit is the limit on the volume that can be quoted for. Up to the specified limit, a trader then has the right, on request, to quote a price at which the bank is willing to transact amounts customary in the trade. Similar to the intraday limit, the quote limit depends on the qualification and function of the trader, the market liquidity of the instrument and the role of the bank in this market.
  • Stop-loss limit limits the maximum loss the bank is willing to accept on a position. If this limit is reached, the trader must close his position, even if he still has a free position limit. It can be withdrawn in addition to the overnight limit.
  • Term mismatch limit : In addition to the overall position limit, this also allows a limit to be set for the open risks in the individual terms. For example, the maximum open position in the intraday limit of a trader can also be limited by, for example, limiting an open position with a term of up to 6 months to a higher amount than for a term of up to 1 year.

Additional restrictions can be achieved through instrument limits , which limit the liquidity risk in the individual markets, and through term limits, which limit the maximum term for individual instruments.

A meaningful functional structure is also important, for example in trading, risk management and support. The traders carry out the actual buying and selling transactions taking into account the limits and strategies. Risk management is responsible for setting and controlling limits as well as developing and monitoring bank-internal strategies for proprietary trading. The supporting functions include the development and operation of information systems, the recording / control of business transactions and the monitoring of regulatory requirements.

You can choose between three different organizational forms in proprietary trading. They differ from one another in the question of where and how a trading book is kept. Then there is a single inventory, multiple inventory and sequential trading model.

The simplest form of organization for proprietary trading is the “Single Inventory Model” . Only one trading book is kept in one place. The sales department markets the products in the trading book on a decentralized basis worldwide; however, the power of attorney to conclude the transaction is incumbent on the traders at the place where the trading book is kept. Risk management and supporting areas are also centralized.

With the “multiple inventory model” , on the other hand, trading books are kept decentrally at at least two international financial centers. The decentralized management is based on the idea that certain financial instruments are regularly traded on defined markets and thus have a so-called "natural home". So could z. E.g. e-bonds would be held in a trading book in Frankfurt, while US Treasuries would be kept in New York. Only the local traders have the power to do business for the respective trading book. To ensure 24-hour trading, after the Natural Home market has been closed, it is possible to pass on limited trading powers for certain positions within specified limits to other parts of the company that are not actually responsible. Risk monitoring takes place locally at the location of the trading book.

The "Sequential Trading Model" is the third and most differentiated form of proprietary trading and is common at banks with central risk management. Trading at different trading venues manages a common asset. There is a single, global trading book for a specific financial product, which is continuously passed on from one location to the next once around the globe in 24 hours. In contrast to the “Multiple Inventory Model”, all traders in the company divisions are granted unrestricted trading permits for all items in the global trading book. For every global book there is a chief trader who controls the trading limits assigned by central risk management and who is responsible for the economic result. The trading models that are delimited here from one another cannot always be delimited from one another in practice.

Accounting

Proprietary trading shops are all in the trading book accounted for because the trading book, all risk positions picks that are held by a bank for the purpose of short-term resale to exploit price and / or interest rates (Art. 4 para. 1 no. 86 Kapitaladäquanzverordnung (abbreviation CRR )). The original and derivative financial instruments traded in proprietary trading are accounted for. In the Financial Accounting Ordinance (RechKredV) (in Section 35 (1) No. 1a RechKredV), the obligation of the financial institution is provided to break down the components of the balance sheet item “trading portfolio” in the appendix . The lists in Section 35 (1) No. 6a to 6c RechKredV serve to make the valuation of the trading portfolio at fair value more transparent. Number 6a RechKredV obliges to specify the essential parameters for calculating the risk discount and the absolute amount of the risk discount. Number 6b is used to explain reclassifications made during the financial year. According to IAS 39.45, all banking transactions are to be given an IFRS category , which clarifies this holding intention. The category Held for Trading (HfT) comes into consideration for trading intentions.

In proprietary trading, realized gains or losses have a direct impact on the banks' income statement . According to the reasons for the 6th amendment to the KWG, “proprietary trading success” is to be understood as the net income or expenses in accordance with Section 340c (1) HGB (trading portfolio). According to Section 340c (1) HGB, the difference between all income and expenses from transactions with financial instruments in the trading portfolio and trading in precious metals as well as the associated income from write-ups and expenses from depreciation must be shown separately (“trading result”). In addition, the trading result includes that part of the current interest , dividends and refinancing components that can be allocated to trading activities. It also includes income from write-ups and expenses from depreciation, as well as expenses for the formation of provisions for impending losses from pending financial transactions and the income from the reversal of these provisions. With the requirement to show the "difference", Section 340c HGB represents an exception to the otherwise prevailing offsetting ban . According to Form 2 of the RechKredV, either the net expense (No. 5) or the net income (No. 3) of the trading portfolio is to be listed ( Form 2 RechKredV). According to Section 34 (2) No. 1d RechKredV, the trading portfolio is to be broken down according to geographic markets.

Future development

Since sustainability does not exist when the markets are highly volatile , sustainable profitability can not be expected from proprietary trading. The customer-driven banking business tended to bring in fewer profits, so that banks around the world began or increased their own trading. However, this turned out to be a frequent cause of banking crises , so that some institutes withdrew from this area in whole or in part. "Anyone who wants more sustainability in their earnings situation and business model has to limit proprietary trading more," said Bundesbank Board Member Andreas Raymond Dombret in September 2012. The Basel III regulations on market risk serve this goal.

According to section 3 (2) sentence 2 no. 3 KWG, automated proprietary trading by CRR credit institutions pursuant to section 1 (1a) sentence 2 no. 4d KWG using a high-frequency algorithmic trading technique is considered a "prohibited business" and is therefore prohibited for the groups of banks concerned. According to the Separation Banks Act , deposit-taking credit institutions are still permitted to conduct proprietary trading with customer reference, i.e. the acquisition and sale of financial instruments for their own account as a service for others. This also includes what is known as “market making”.

The EU Separate Banks Regulation of January 2014 defined in Art. 5 No. 4 EU Separate Banks Regulation as “entering into positions with the help of one's own capital or funds raised in any type of transaction that involves buying, selling or has the object of any other acquisition / or other sale of any financial instrument or any commodity and its sole purpose is either to generate profit for its own account, without any connection to an actual or anticipated customer activity ... "Proprietary trading was therefore in Art. 6 Separate Banks Regulation has been banned. The EU Separate Banks Regulation was withdrawn in July 2018 and did not achieve the status of an EU regulation .

See also

Individual evidence

  1. ↑ Jürgen Krumnow / Ludwig Gramlich / Thomas A. Lange / Thomas M. Dewner (eds.): Gabler Bank-Lexikon , 2002, p. 1107
  2. ↑ Kaspar von Stieler, Teutsche Secretariat-Kunst , 1674, p. 166
  3. ↑ The term propre trade was also common. (Meyers Großes Konversations-Lexikon, Volume 5. Leipzig 1906, p. 441).
  4. ↑ Jonas Ludwig von Heß: Hamburg topographically, politically and historically described , 1811, p. 303, digitizedhttp: //vorlage_digitalisat.test/1%3D~GB%3D1J1OAAAAcAAJ~IA%3D~MDZ%3D%0A~SZ%3DPA303~ double-sided%3D~LT%3D~PUR%3D
  5. ^ Eucharius Ferdinand Christian Oertel: Foreign dictionary in German written and colloquial language from all subjects of human knowledge and activity , Volume 2, 1840, p. 694, digitizedhttp: //vorlage_digitalisat.test/1%3D~GB%3DxuVIAAAAcAAJ~IA%3D~MDZ%3D%0A~SZ%3DPA694~ double-sided%3D~LT%3D~PUR%3D
  6. ^ Hansschichtel , The Essen-Düsseldorfer Börse in the post-war period , 1928, p. 25
  7. ^ Hermann Staub / Claus-Wilhelm Canaris, Commercial Code: Grosskommentar, Volume VI, 2004, § 400 Rn. 8th
  8. ↑ Protocols of the "Commission for Advising an ADHGB", Volume III, 1858, p. 1211
  9. ↑ Arthur Nussbaum, Facts and Terms in German Commission Law , 1917, p. 67 ff.
  10. ↑ Otto Burchard, The fulfillment transaction at the securities purchasing commission in a comparative legal representation , 1932, p. 6
  11. ↑ Carl Zimmerer, Banking Act: Systematic Introduction and Commentary , 1962, p. 102
  12. ↑ a b Martin Faust, Determination of the cost of equity in the context of value-oriented corporate management of credit institutions , 2002, p. 237
  13. ^ Ernst Heymann, Commercial Code (without Maritime Law): Third Book. Paragraphs 238-342a , 1999, § 340c, Rn. 7th
  14. ↑ Ralf Plück / Peter Kühn / Karl Jürgen Schmutzler, Capital Market Law: Legal Regulations and Liability Risks for Financial Service Providers , 2003, p. 29 ff.
  15. ↑ Oliver Everling / Karl-Heinz Goedeckemeyer, Bankenrating: Normative Bankenordnung in der Finanzmarktkrise , 2015, p. 396
  16. ↑ Oliver Seiler / Martin Kniehase in: Herbert Schimansky / Hermann-Josef Bunte / Hans-Jürgen Lwowski, Bankrechts-Handbuch , Volume 2, 2007, § 104 Rn. 21st
  17. ^ Ernst Heymann, Commercial Code (without Maritime Law): Third Book. Paragraphs 238-342a , 1999, § 340c, Rn. 8th
  18. ^ BGH, judgment of November 6, 2003, Az .: 1 StR 24/03
  19. ↑ BaFin, Notes on the facts of proprietary trading and proprietary trading , last amended on October 24, 2014
  20. ↑ BGH WM 2012, 1520 Rn. 19th
  21. ↑ Regulation (EU) No. 600/2014
  22. ↑ Petra Buck-Heeb, Capital Markets Law , 2014, p. 44
  23. ↑ Theodor Heinsius / Arno Horn / Jürgen Than, Commentary on the Depot Act , 1975, p. 537 f.
  24. ↑ Thomas Hartmann-Wendels / Andreas Pfingsten / Martin Weber, Bankbetriebslehre , 1998, p. 19
  25. ↑ Birgit Stefanie Pawelka, Investment Banking Strategies of German Banks , 2003, p. 59
  26. ↑ a b Deutsche Bundesbank, Monthly Report October 2004 , p. 40
  27. ↑ Played, deceived, cheated . In: Der Spiegel . No. 13 , 1975 ( online - March 24, 1975 ).
  28. ↑ Played, deceived, cheated . In: Der Spiegel . No. 15 , 1975 ( online - Apr. 7, 1975 ).
  29. ↑ Markus Witt: The proprietary trading of universal banks: organizational structure, proof of success and control options . Springer-Verlag, 2013, ISBN 978-3-322-92419-3 , pp. 2, 3 ( limited preview in Google Book search).
  30. ^ Deutsche Bundesbank, Monthly Report September 2005 , p. 21
  31. ^ Deutsche Bundesbank, Monthly Report September 2009 , p. 37
  32. ↑ a b Deutsche Bundesbank, Monthly Report September 2009 , p. 41
  33. ↑ Deutsche Bundesbank, Monthly Report September 2009 , p. 44
  34. ^ KPMG, Global Trading. Aspects of Global Trading - Taxation, Accounting, Regulatory and Risk Management , 1993, p. 7 ff.
  35. ^ Mario Straßberger, Global proprietary trading of banks , November 2001, p. 7.
  36. ↑ LB Samuels / PA Brown, Observations on the Taxation of Global Securities Trading , in: The New York University Tax Law Review, 1990, pp. 537 ff.
  37. ^ KPMG, Global Trading. Aspects of Global Trading - Taxation, Accounting, Regulatory and Risk Management , 1993, p. 14 ff.
  38. ↑ this process is called "passing-the-book"; LB Samuels / PA Brown, Observations on the Taxation of Global Securities Trading , in: The New York University Tax Law Review, 1990, p. 542.
  39. ↑ Andreas Dombret, Business Models and Bank Structure from the Perspective of Financial Stability , lecture on the occasion of the 16th Bank Symposium on September 20, 2012
  40. ↑ Oliver Everling / Karl-Heinz Goedeckemeyer, Bankenrating: Normative Bankenordnung in der Finanzmarktkrise , 2015, p. 66