Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act 2010, also known as the “Volcker Rule”, prohibits banking entities, which benefit from federal insurance on customer deposits or access to the discount window, from engaging in proprietary trading and from investing in or sponsoring hedge funds and private equity funds, subject to certain exceptions. The Study suggests that proprietary trading in banking entities is speculative and recommends a supervisory framework that effectively prohibits proprietary trading activities throughout a banking entity, and not just within certain business units. However, this objective is complicated by the fact that the Volcker Rule includes a number of specific statutory exceptions to the prohibition (market-making, risk mitigating hedging, underwriting and others) which involve acting as principal and which, in certain circumstances identified in the Study, could constitute proprietary trading. The Study seeks to assist in dealing with these issues by identifying indicia of permitted activities (specifically, for market-making, hedging and underwriting) that are intended to help banking entities determine what activities constitute impermissible activities. The FSOC Study notes that this process will present many challenges and goes on to cite nine specific examples of where a transfer from permissible to impermissible activities may occur. The Study recommends a "Programmatic Compliance Regime" that includes internal policies and procedures, internal quantitative and other controls, recordkeeping and Studying systems, independent testing, and Board and CEO accountability (the latter in the form of a public certification to the compliance regime's effectiveness.) In furtherance of compliance, the Study recommends that the implementing regulatory agencies require banking entities to study on quantitative metrics that may assist in identifying impermissible activities. The FSOC noted four potential categories of such quantitative metrics, including (i) Revenue-Based Metrics, (ii) Revenue-to-Risk Metrics, (iii) Inventory Metrics, and (iv) Customer-Flow Metrics.