The Case for Commingling Accounts When The Account includes Gold

In addition, foreign exchange rate contracts
and gold contracts would be combined

in Memorandum items 2 and 3, whereas
each of these two types of contracts
currently is reported separately in
Memorandum item 2.

Click to access FFIEC031_FFIEC041_20140623_ifr.pdf

“Currently” above means December 2014 and earlier.   Today Gold is mixed in with FX, which not only gives question to gold activity, but FX activity.    This is not a prudent way of doing things if your an accountant that seeks transparency.    Folks still deserve to know the “why”.   Normally the “why” is explained in the Federal Register, but not this time.    Now, not only gold in the vault is reported on the same line item as gold leased out at the Fed/Treasury but now the banks can report gold and Foreign Exchange (FX) derivatives on the same line item!     Interestingly, the “Final” Federal Register notice omits the clause presented above, yet the commingling of FX and Gold has been implemented in the March 2015 cycle.

I have to think this may have something to do with the crazy derivative activity in precious metals in the March 2015 OCC derivatives report.

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