Over on FierceFinance, we noted recently that the Financial Stability Oversight Council, which has been tasked with finding ways to prevent another financial crisis, released a study recommending regulators mandate a 'public attestation' on Volcker Rule compliance. The idea is that forcing CEOs to personally sign off on the firm's efforts to comply will result in greater accountability to the spirit of rule.

We noted this was similar to the attestation requirement in Sarbanes-Oxley, which forces the CEO and CFO to sign off on the veracity of financial statements and the soundness of the firm's 404(b) efforts.

The idea of someone standing up on behalf of the company to say they have done what they could to comply with the spirit of the rule holds a certain intuitive appeal.

However, the Financial Times doesn't think much of the idea. "By all means tame the banks, but in the department of unintended consequences, this part of the FOSC's recommendations could be storing up big trouble."

Many wonder if broker-dealers can realistically devise systems that can separate proprietary trades from agency trades. It's certainly true that the 404(b) process ended up being quite costly and ornate from a technical point of view. And yet in the end, many would say the law was worth it, that company financial statements were improved.

I do not think the procedural work involved in a Volcker Rule sign-off would be anything close to the sign-off required by 404(b), which governed the most important financial controls. Still, I doubt we'll see a sign-off required anytime soon. The political mood doesn't favor it.

For more:
- here's the article

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