Subject: File No. S7-41-11
From: Suzanne Shatto

October 24, 2013

“If a banking organization has to connect its hedging activity to a specific contract or position, I think the concern may be that there may be incomplete hedges,” Kini said in an interview. “The viability of that hedging exemption is very important for the safety and soundness of banking organizations.”
http://www.bloomberg.com/news/2013-10-23/volcker-rule-hedging-exemption-said-disputed-by-gensler-stein.html

you know, if you cannot connect the hedging to a certain position, then it is not hedging - it is proprietary trading.