(1) Accounting risk. Its risks include: 1, accounting basic work risk. The basic work of bank accounting lies in the true, complete and timely accounting of economic and business organizations. If the accounting method is inaccurate, the accounting procedure is not standardized and the accounting quality is not high, it will easily lead to risks. Daily cash receipt and payment, voucher acceptance and audit, account application, account login and settlement are all directly or indirectly related to risks. 2. Final risk. Commercial banks pay attention to efficiency, which objectively requires them to have a perfect scientific management system with financial assessment as the core on the premise of meeting market demand: financial reports are the main basis for assessing the operating performance of banks at all levels. The most direct and important information of financial quantitative evaluation is the accounting information provided by financial reports. Due to some behaviors, such as completing the tasks assigned by the superior, absorbing high-cost funds, the proportion of bad debts and bad debt reserves is wrong, the standard of interest receivable is unreasonable, and less interest payable is raised. The profits of banks are all false profits and real losses. 3. Assess risks. Failing to carefully analyze and judge the financial reports provided by customers, overestimating their solvency and operating level, resulting in potential risks; Exaggerate the quality of credit assets internally, and pass the infeasibility analysis report under the cover of false accounting information, resulting in the risk of credit assets loss. (2) Risks of accounting settlement business. Settlement business refers to the settlement of various bills, which plays an important role in the intermediary business of banks, and its risks mainly include: 1, fraud risk. Fraud risk is a premeditated and organized large-scale bill fraud by criminals taking advantage of their familiarity with banking business, taking bank bills and bank acceptance bills as the targets and tools, supplemented by high-tech means. 2. Overdraft risk. It means that customers use the credit card in "three tickets and one card" as a crime tool to make malicious overdrafts. This kind of risk is mainly that overdrafts commit crimes by taking advantage of loopholes and time difference in bank management, which will cause great economic losses to banks in serious cases. 3. The risk of difficulty in identifying true and false bills of exchange. Due to the continuous improvement of fake ticket means and the relative backwardness of bank identification means, the risks in this respect still exist. 4. Discount risk of bills of exchange. After the bill expires, the discount bank cannot recover the discount amount. 5. Accept the risk. After the bill expires, the funds in the drawer's account are insufficient to pay. (3) Internal control risk. This risk is mainly manifested in the following aspects. 1. Some bank accountants have low quality, do not take the initiative in service, and have irregular operation behaviors, which are prone to accounting accidents. 2. Some bank personnel have low quality, collude internally and externally, and wantonly infringe on the interests of banks, thus causing economic cases. 3. The lack of proper mutual restraint and containment in the setting of accounting posts has led some personnel to operate illegally, and even embezzle and misappropriate bank funds, which has brought risks to banks. (D) Risks brought by backward accounting methods.
What risks does the bank's main business face?
China Commercial Bank mainly faces the following risks:
(1) Credit risk: the risk that the counterparty cannot perform the contract;
(2) Market risk: the risk that the bank's on-balance sheet and off-balance sheet positions suffer losses due to changes in market prices;
(3) Interest rate risk: refers to the risk faced by the financial position of the bank when the interest rate fluctuates adversely.
(4) Liquidity risk: refers to the situation that a bank cannot provide financing for the reduction of liabilities or the increase of assets, that is, when the bank is short of liquidity, it cannot quickly increase liabilities or realize assets at a reasonable cost to obtain sufficient funds, thus affecting its profitability;
(5) Operational risk: mainly lies in the failure of internal control and corporate governance mechanism;
(6) Legal risk: including the risk that the value of assets decreases or liabilities increase due to imperfect and incorrect legal opinions and documents;
(7) Reputation risk: This risk stems from operational errors, violation of relevant laws and regulations and other issues.
The following is a brief analysis of the above risks:
First, credit risk.
This is the main risk of commercial banks, which refers to the possibility that debtors with bank credit support cannot repay the principal and interest in full and on time according to the contract. In today's diversified business of commercial banks, not only the traditional credit risk is still the main risk of commercial banks, but also the credit risk involved in discount, overdraft, letter of credit, interbank lending and securities underwriting. Credit risk mainly includes the following categories: principal risk refers to the possibility that the bank's right of recourse against a customer cannot be realized. For example, non-performing loans will eventually show principal risk and potential substitution risk, that is, the risk of losses caused by the counterparty's default due to market price fluctuations from the trading day to the delivery day. Its size is calculated according to the maximum loss that may be caused when the market trend is contrary to the original expectation. For banks, it may be that the counterparty defaults and the market develops in an unfavorable direction, and they are forced to change their counterparties to complete the original transaction. Third party guarantee risk. If the debtor defaults and the guarantor or promisor can't repay the debt on behalf of the debtor, there will be third-party guarantee risk, securities trading and underwriting risk, which refers to the risks in the secondary market trading and primary market trading of securities. Settlement risk refers to the risk that may be caused by the difference between the notice time and the actual time during the settlement of funds or securities. Once the relevant settlement cannot be executed or mistakes occur, this risk will be transformed into principal risk. The risk of credit concentration refers to the fact that the bank's loans are only granted to a few customers, or the loans to a certain customer exceed a certain amount of its total loans.
Second, interest rate risk.
It refers to the possibility that the fluctuation of interest rates in the money market and the capital market will affect the economic losses of commercial banks such as debt costs and asset returns through deposits, loans and borrowings.
Third, liquidity risk.
It refers to the possibility that the bank's own current assets can't meet the need to pay the due liabilities immediately, which makes the bank lose its solvency and cause losses. Liquidity risk, on the one hand, is a primitive risk, which is caused by insufficient liquidity; On the other hand, it is also the most common situation. Other kinds of risks are hidden and accumulated for a long time, and finally break out in the form of liquidity risk. In this sense, liquidity risk is a derivative risk, that is, lack of liquidity, which may be caused by interest rate risk, credit risk, operational risk, management risk, legal risk, national risk, exchange rate risk and other risk sources, and banks eventually fall into liquidity risk.
Fourth, exchange rate risk.
It refers to the possibility that the exchange rate of local currency or foreign currency will appreciate or depreciate, which will make the assets of commercial banks suffer losses in the process of holding or using them.
Verb (abbreviation of verb) market risk
Refers to the possibility that commercial banks will suffer losses due to fluctuations in market value when investing or buying and selling movable property and real estate, which mainly depends on changes in market conditions such as commodity market, money market, capital market, real estate market, futures market and option market.
Legal risks of intransitive verbs
It refers to the possibility that the bank will face losses due to the ambiguity, change, misunderstanding, ineffective implementation and careless provisions of the legal provisions.
Seven. operational risk
Refers to all kinds of natural disasters, accidents, loss of procedures or control in the daily operation of commercial banks; & gt
How to prevent the operational risk of accounting settlement business
I. Problems encountered by bank accountants in the execution of court deduction business 1. Bank accountants are not familiar with the court deduction business, and improper handling of related business brings operational risks. If some bank accountants handle the frozen deduction business under the condition that the certificates and legal documents provided by the court executives are incomplete; Some court executives left the relevant legal documents in the bank after a dispute with the bank accountant, but the bank accountant did not know that the court lien was effective and did not go through the corresponding formalities in time, which led to the court issuing a fine notice later. At present, the problems exposed by banks in assisting the court in inquiry, freezing and deduction are mostly manifested in not strictly observing the relevant regulations and procedures of the People's Bank of China, lax management of business operation authority, formalization of internal supervision mechanism, and unfamiliarity of specific managers with relevant laws and policies. 2. Because there are many channels for enterprises to handle settlement business, its deposit balance is difficult to control, and bank accountants are prone to make mistakes when issuing relevant receipts to the court. This requires the bank accountant to declare and communicate with the court staff first, and take the initiative to ask what the court wants to achieve. If there is still money after the inquiry, the money will be deducted. First, set the account of the executed company to the state of only receiving and not paying, and then write the balance of the inquiry ... (This article * * * counts 1 page) [Continue reading this article]
Main risks of bill business
In recent years, China's bill business has developed rapidly, which benefits from the rapid growth of China's economy and the increasing demand for short-term financing by enterprises. As a financing tool among enterprises, banks and enterprises, bills have both settlement and financing functions. At the same time, bills have become the focus of domestic financial institutions because of their high liquidity and stable income. Under the policy of national macro-control, reducing the scale of credit and restraining the overheated investment in some industries, bill financing business has become the main channel for enterprises to solve the shortage of funds and the main business for financial institutions to achieve new profit growth points. However, it cannot be ignored that there are also great risks in the bill business. From the risk of bill business, there are acceptance bank risk, bill holding risk, discount risk, repurchase risk, transfer risk and transfer risk. 1. Financing risk is the risk caused by banks discounting acceptance bills without real trade background. Financing acceptance bill is a bank acceptance bill obtained by enterprises through issuing false trade contracts to alleviate their own capital turnover difficulties. Because enterprises can't provide real trade contracts and VAT invoices, if banks discount such acceptance bills, they can't rediscount them in the central bank or other financial institutions, so they will inevitably face the problem of capital turnover, that is, liquidity risk. If the current financing cost is higher than its discount rate, the interest rate will be upside down, which will affect the bank's operating income and form a benefit risk. At the same time, since bills of exchange are issued under the condition of difficult cash flow of enterprises, although banks must collect corporate deposits when issuing acceptance bills, most of the sources of deposits in the current market are the rolling issuance of discounted bills. If bills of exchange cannot be accepted in time, it will inevitably lead to the risks of accepting banks. 2. Operational risk refers to the risk that banks discount defective bills or forge or alter bills by mistake due to careless operation or lax examination when handling the discount business of acceptance bills. Bank acceptance bills are important securities, and only the items specified in the Bill Law are legal bills. Any flaw in the face or endorsement will cause the payment and settlement risk of the discount bank. The lack of basic knowledge of bills by settlement personnel will lead to ineffective implementation of internal control system. There are many problems in grass-roots banks, such as shortage of bill professionals, insufficient training, insufficient bill identification equipment and so on. In addition, in order to attract customers, some business personnel operate and open accounts in violation of regulations, reduce the bill settlement fee standard, and do not operate bill verification as required, which increases the payment risk of bills. 3. Moral hazard Moral hazard means that some lawless people in the society or in banks use forged or altered bills, "clone" bills, "switch bills" or forge, falsely open VAT invoices, forged or altered trade contracts and false bank inquiry letters to consciously defraud bank funds, thus exposing banks to the risk of financial losses. 4. Credit risk refers to the risk that after the bank acceptance bill expires, due to the tight capital position of the accepting bank, the bank acceptance bill is postponed or not accepted, or the accepting bank fails to keep its promise, deliberately suppresses the bill and cannot withdraw money in time, which makes the discount bank face. As an intermediary business, some accepting banks relax the examination and conditions, and issue a large number of bank acceptance bills beyond their own ability, which leads to the extreme expansion of bank credit and the failure to pay in advance when the acceptance expires, which is risky. 5. The risk of bill storage refers to the risk that the bill is damaged, lost or stolen due to improper storage. The custody risk of bills is accompanied by the whole process of bill business, such as the custody risk of blank bills, the custody risk of bank acceptance bills, the custody risk of discounted bills, the custody risk of transferred bills, the handover risk of bills and so on.
What are the risks of the payment system in the process of payment and settlement?
I. Existing problems
(A) the operation and management mechanism needs to be further improved.
Since the operation of the modern payment system, although the management department has formulated some business operation rules and system maintenance methods in time according to its business processing characteristics, it lacks corresponding business guidance and supervision and inspection on the implementation of the payment system, which makes the operation and management of the payment system have loopholes. Due to the lack of smooth communication channels, it is impossible to respond quickly when there are problems in system operation, effectively start emergency plans, and deal with emergencies in time, which may lead to serious consequences.
(b) The technical strength of personnel needs to be further strengthened.
Modern payment system is a huge and complex system, which connects all banking institutions and related business systems, supports the application of various payment tools, and has a wide range of support and many business types. However, due to the influence of the current system and other factors, the personnel allocation is not satisfactory, the personnel are not stable enough, and the technical force is seriously lacking, which easily leads to the operational risk of the payment system.
(C) Pay risk awareness needs to be further strengthened
After the operation of the modern payment system, some front-line personnel have poor work initiative, only satisfied with basic work such as entry and audit, and lack sensitivity to new problems in their work. In addition, some grass-roots managers lack a sense of work identity and honor, and think that work risks are heavy, relatively monotonous and boring, and personal development opportunities are few. They are careless in their work, turn a blind eye to potential risks, and it is easy to bury potential risks.
(D) The internal control mechanism of payment risk needs to be further strengthened.
First, breaking the rules is the main reason for the formation of cases and major accidents. Some units are poorly staffed, and the rules and regulations exist in name only. In particular, some grass-roots outlets often have vacuum and loopholes due to insufficient staffing, which makes the business mutual restriction mechanism not implemented and brings opportunities to criminals. Second, supervision and inspection are not in place. The system of regular and irregular surprise inspections by superiors to subordinates and supervisors to operators did not maintain effective continuity, which affected the effect of supervision and inspection. Afterwards, the supervision department still focuses on the supervision of accounting vouchers and materials, which can only ensure the correctness of the accounting business it supervises, but can't confirm the real intention of the business, and can't find out the collusion of criminals and the use of real bills in real time. Third, there is no perfect risk assessment mechanism. Risk management needs a unified and complete risk identification, evaluation and information feedback system to ensure that risk management is always unremitting.
Second, the main measures to prevent the risk of payment and clearing system
To strengthen the risk prevention of payment system, we must pay equal attention to education, system and supervision, and comprehensively manage potential risks by solving deep-seated problems such as laws, regulations and management system.
(a) improve the payment and settlement laws and regulations and rules and regulations system.
With the progress of science and technology, the increasing number of e-commerce, the gradual refinement of payment services and the development of financial markets, the People's Bank of China should closely follow the needs of the development of electronic payment settlement and further strengthen the construction of relevant laws and regulations in combination with the actual business of grassroots banks. The rules and regulations that have not met the needs of business development should be abolished in time, and the management of the transitional period of important local businesses such as bill clearing in the same city should be strengthened, and a unified management system should be formulated. It is necessary to start the revision of Bill Law in time; Improve online payment and other electronic payment business rules, and formulate relevant supporting rules such as the Measures for the Administration of Payment and Clearing Organizations. Take the completeness of laws and regulations to prevent and resolve payment risks.
(2) Create a safe and efficient supervision environment for the payment and settlement system.
The focus of payment and settlement work should be to pay equal attention to service and management, strengthen the sense of responsibility and risk, and create a supervision environment of payment system that pays equal attention to safety and efficiency.
First of all, we should further study and explore the scientific salary system management model. Strengthen mutual cooperation and close cooperation among departments, establish a scientific and reasonable organizational mechanism, further straighten out the relationship between internal management and business development, and build a clear, clear and efficient payment management system.
The second is to further cultivate the risk prevention culture of the payment system. It is necessary to make all participants and related staff in the payment system have a strong sense of risk prevention and control, actively participate in risk control, constantly enhance their awareness of self-discipline and heteronomy, overcome the adverse cultural influence of "replacing management with trust, replacing system with habit, and replacing discipline with family", create a cultural atmosphere of case risk prevention and anti-corruption, and make the payment system internal ...
What are the risks of off-balance-sheet business of commercial banks?
According to the current regulations of the People's Bank of China, it can be roughly divided into three types: guarantee, commitment and financial derivative transactions.
Guarantee business refers to the business that a commercial bank accepts the entrustment of customers and assumes the responsibility to a third party, including guarantee (letter of guarantee), standby letter of credit, documentary letter of credit, acceptance, etc.
Commitment business refers to the agreed credit business provided by commercial banks to customers on a certain date in the future according to the agreed conditions, including loan commitment.
Financial derivative transactions refer to the derivative transactions of currencies and interest rates such as forwards, swaps and options conducted by commercial banks to meet the needs of customers' hedging or their own position management.
According to the current accounting standards, businesses that are not recorded in the balance sheet and do not form real assets and liabilities, but can change profits and losses, are all off-balance sheet businesses.
What are the risk control measures of banks?
1. The main risk of banks is credit risk, of which loan risk is the main content. When a bank wants to lend a loan to a customer, the general premise is that the customer and the bank have a long-term settlement relationship and a running account. More importantly, the account manager will chat with corporate finance to understand the business situation and capital needs of the enterprise. Traditionally, he does not deal with strange customers. When the enterprise meets certain conditions, banks begin to intervene in credit lending, including actively selling credit products to customers or actively applying for loans by customers. The borrower makes daily settlement through the loan bank, and the bank can find some information by looking at the account transaction (not all, more information depends on the daily chat and visit between the bank and the enterprise). For example, the borrower recently borrowed 6.5438+million yuan and bought 6.5438+000 cars, so after paying 6.5438+million yuan, under normal circumstances, car sales revenue will come in one after another. If there is no income within a month, then the bank will be very nervous! ! !
There are also borrowers who pay taxes and utilities through banks, and wages are paid through banks. Banks can judge whether there is a major change in the operation of enterprises by observing whether the payment of enterprises is interrupted or obviously reduced.
Analyzing the account transaction process itself is a skill, and the process is closely related to the parameters of the banking system. This is different from a loan company without settlement business. They don't have a settlement network. Although loan companies can ask customers for running water, on the one hand, running water can be PS, and the parameters of running water format of different banks are very different. How does a loan company identify authenticity? Even if it is true, how to identify valid information? Moreover, the banking system is not regularly updated and upgraded, and many of the same subjects are entered in a variety of ways. Running water needs to be analyzed, but not all.
The so-called bank credit risk control is a thorough and meticulous understanding of every detail, not an empty theory like FRM. Therefore, if you want to control the bank's style, you must first be familiar with the bank's settlement system, public and private.
Many internet companies also have ways to control risks through some internet information, similar to human flesh search, using big data, data mining, machine learning, anti-fraud and other calculations to operate in batches. This is a meaningful attempt. Internet companies are burning money at present, and what a mature business model will be is still unknown. Big data is of course important, and as bankers, we often care about small data, small data related to our customers. Settlement data is similar to sampling, which extracts cash flow information that best represents the risk status of customers from thousands of variables of customers. Sometimes the cash flow analysis is done well, and it can be judged that the risk is 80%. Of course, some social network information of customers, such as Weibo and qq information, is sometimes important, so it should be regarded as an early warning information. For those small and micro loans, customers are at the bottom of society, not in the financial system, and there is no account, let alone settlement. They can only use the Internet to catch the blind, and it is better than nothing. It is safer for banks to give up these customers directly.
Familiar with guarantee. The first source of repayment has been discussed earlier. Let me talk about the second source of repayment.
Collateral: be familiar with all kinds of collateral, real estate, the types of real estate, and what are their policy risks? How to apply for mortgage registration? His arrest warrant is also fake. I've experienced it myself. Housing Authority colludes with borrowers to defraud hundreds of millions of loans! ! ! How to handle the equity pledge and which part to accept? What if there are risks? What are the obstacles? How to manage the car mortgage? How to tow a car?
So bank risk control is these trivial things. A small detail is out of control, which is a loophole of hundreds of millions! ! !
2. Technology and management. I have done risk management for ten years and talk about my own experience.
When I was young, I thought I should be a professional and studied many VBA\SAS\CFA\FRM\ risk case models. In fact, I discovered later that it still depends on team, management and resource integration. It is another kind of ability. Professional knowledge can be remedied, but the improvement of ability is not easy. He clearly knows what to do, but specific things need to be done. There is something wrong with the quality of his people, and no matter how strong the risk control system is, it will not help. Civil air defense and physical defense technology. There is too much emphasis on technology now, such as using big data modeling to screen credit customers ... >>
What is the settlement risk exposure?
The credit business is exposed because it is guaranteed.
There is no exposure to the settlement business, which is mainly operational risk.
Risk points that need to be paid attention to in the process of bank personal settlement and account opening
Personal bank settlement accounts are relative to "savings" accounts. In the past, the People's Bank of China defined an account opened by an individual in a bank as a "savings" account, that is, an account for depositing and withdrawing money.
However, in recent years, with the expansion of banking business, personal bank accounts are no longer just for depositing and withdrawing money, but can perform settlement functions such as payment, transfer and remittance. Therefore, the banking industry in China redefines and distinguishes individual bank accounts.
An account dedicated to deposit and withdrawal is defined as a savings account (if someone handles the remittance settlement business for you, you won't receive the money).
Personally, I think this simple account will soon quit the historical stage.
Now individuals go to the bank to open an account, and the bank will prompt customers to sign the agreement of "personal settlement account".
You can decide whether to open a personal bank settlement account according to your business needs.
What are the risks of the exchange? Pray for the great gods.
China Financial Futures Exchange's risk management of stock index futures mainly includes: (1) margin system: margin is divided into settlement reserve and trading margin. The trading margin standard is stipulated in the futures contract. In the course of futures contract trading, under any of the following circumstances, the exchange may adjust the trading margin standard according to the market risk and report to the China Securities Regulatory Commission: ① there is a continuous price limit in the same direction; ② In case of national statutory holidays; ③ The Exchange believes that the market risk has increased significantly; ④ Other circumstances deemed necessary by the Exchange. If the futures contract is adjusted to meet the trading margin standard, the exchange shall settle all positions of the contract in accordance with the new trading margin standard at the time of settlement on the same day. If the margin is insufficient, it shall be added before the market opens on the next trading day. (2) Price limit system The price limit system is divided into fuse system and price limit system. The range of daily fuse and price limit shall be set by the Exchange, and the Exchange may adjust the range of fuse and price limit of futures contracts according to market conditions. The fuse range of stock index futures contracts is 6% of the settlement price of the previous trading day, and the price limit range is10% of the settlement price of the previous trading day. There is no price limit on the last trading day. After the daily opening, the declared price of the stock index futures contract touches the fuse price for one minute, and the contract starts the fuse mechanism. (1) Within ten minutes after the fuse mechanism is started, the contract transaction declaration will continue to match the transaction within the fuse price range. After ten minutes, the fuse mechanism is terminated and the price of the daily limit board takes effect. ② If the market suspends trading less than 10 minutes after the fuse mechanism is started, the fuse mechanism will be terminated, and the price fluctuation ceiling price will take effect after the transaction is restarted. (3) Do not start the fuse mechanism within 30 minutes before closing. If the fuse mechanism has been started, continue to perform until the end of the fuse period. ④ Only start the fuse mechanism once a day. (3) Limited position system Limited position refers to the maximum number of positions that a member or investor can hold in a contract calculated unilaterally according to the provisions of the exchange. When the same investor opens positions in different members, the total position of a contract shall not exceed the position limit of one investor. The specific provisions of the stock index futures contract on the position limit of members and investors are as follows: ① An absolute position limit of 2000 lots is imposed on the unilateral position of investors in a single contract. ② If the total contract position (unilateral) exceeds 654.38+ million lots, the total position (unilateral) of a clearing member in the contract shall not exceed 25% of the total contract position. (3) The positions held by members or investors who have obtained the hedging quota are not subject to this restriction. Members and investors who exceed the position limit may not open positions in the same direction. (IV) Large-sum account declaration system If the investor's position meets the position declaration standards set by the Exchange, the investor shall declare to the Exchange through the trustee. The Exchange may, according to the market risk status, formulate and adjust the reporting standards for positions. Investors whose positions meet the reporting standards of the exchange shall report to the exchange before the close of the next trading day. The ownership of the transaction requires investors to make supplementary reports. Investors who meet the reporting standards of the Exchange shall provide the following materials: ① A report form for large investors, including member name, member number, investor name and trading code, contract code, positions, trading margin and available funds; (2) explanation of the source of funds; ③ Information of the actual controller of the legal person investor; (4) the account opening information and settlement documents of the day; ⑤ Other materials required by the Exchange. (V) Compulsory liquidation system Compulsory liquidation refers to the compulsory liquidation measures taken by the Exchange against its members and investors in accordance with relevant regulations. Under any of the following circumstances, members and investors will be forced to liquidate their positions: ① the balance of members' settlement reserve is less than zero and cannot be replenished within the prescribed time limit; (2) The position exceeds the position limit standard and fails to close the position within the prescribed time limit; (3) Being punished by the exchange for compulsory liquidation due to violation of regulations; (four) according to the emergency measures of the exchange, it should be forced to close the position; ⑤ Other positions should be closed by force. Enforcement principle of forced liquidation: Forced liquidation shall be implemented by members first, and the time limit shall be the first quarter after the opening of the market unless otherwise stipulated by the Exchange. If the member fails to complete the execution within the prescribed time limit, it shall be enforced by the exchange. Execution procedures for compulsory liquidation: ① Notice. The Exchange shall issue a compulsory liquidation request to the relevant clearing members in the form of the Notice of Compulsory Liquidation (hereinafter referred to as the Notice). Unless specially delivered by the Exchange, the notice is sent with the settlement data of the day, and the relevant settlement members can obtain it through the Exchange system. ② Execution and confirmation. 1. After the opening of the market, the relevant members will close their positions by themselves until they meet the closing requirements; 2. The clearing member exceeds the requirements ... >>