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SOME on Wall Street casually call it the “anti-Deutsche Bank rule” because of its potential impact on Germany’s biggest bank. In truth, it should probably be known as the “anti-globalisation rule” for the chilling effect it may have on cross-border banking almost everywhere. 由于受到德意志最大银行的潜在影响，华尔街部分人称它为‘反德意志银行准则’。事实上，对于全球跨境银行所产生的“寒蝉效应”更应该冠名“反全球化准则”的称号。 At the end of this month the Federal Reserve will close its consultation period on proposals to reshape the regulation of foreign banks’ operations in America. The main proposals will overturn rules from the early 2000s that, in effect, allowed subsidiaries of well-capitalised foreign banks to operate in America without having to meet minimum capital requirements. Under the new proposals, foreign banks will have to ring-fence their American operations into separately capitalised and regulated subsidiaries; they may also have to be separately funded. 在该月末，为了重整美国的跨国银行的运营监管，美联储建议暂停咨询服务。实际上，在无小额资本要求下允许资本雄厚的跨境银行美国设立分行。而在2000年早期，建议取缔该准则。新规之下，美国的跨国银行将必须维护独立投投资和总行监管的运营模式。也许他们不得不单独融资。 The finer details—such as whether parent companies can use debt to inject capital and funding into their subsidiaries—are still being haggled over. But if imposed in their strictest form the new rules may have big consequences. 详细说来：像总公司是否使用外债注入资本并将基金存入分行仍然处于争论中。但是新规定的严格执行将产生很大的影响。 Huw van Steenis, an analyst at Morgan Stanley, reckons that Deutsche Bank has a capital shortfall of as much as $20 billion in its American operation (see chart above). That may be reduced to $7 billion-9 billion if it cuts the size of its American balance-sheet by about a third. Even so, the cost of additional capital and the loss of earnings from shrinking its American business may be significant. Barclays, too, may have to inject capital into its American business, which holds about a fifth of its total assets. MS的分析师HVS估计：德意志银行在美国运营时期，出现将达20亿欧元的短期资本断列，如果断裂切断三分之一的资产负债表也许会减少7亿到9亿欧元。附加资本的成本和美国商业利润的缩水也许更具象征性。Barclays也由不得将总资产1/5的股本注入美国商业。 To some extent, these two banks are facing the consequences of their own actions. Over the past two years Deutsche and Barclays have deregistered their American bank-holding companies to avoid some provisions of the Dodd-Frank act that would have forced them to inject more capital into the businesses. “Barclays and Deutsche brought it on themselves,” says a senior executive at a large American rival. 某种程度上，两家银行都面对着自己行为的影响，在过去的两年里，为了避免D-BANK里的规定，被强迫向商业中注入更多资本，D和B银行已经注销了各自的美国分行股票备案，股票份额他们自己持有。美国最大的竞争对手银行高管说。