Commodity firms - systemic risk?

The structure of commodity markets is changing. Banks will be getting out of this business based on the poor returns over last few years and the impact of Dodd-Frank and more importantly the Volcker Rule.  Banks are more focused on core businesses and will jettison those that are not making or will not make higher ROE's. Out goes commodities which have started to slow relative to the go-go years of the super cycle. 

However, there is an undercurrent within the commodity markets that perhaps the key non-bank trading houses represent a systemic risk. If banks are a systemic risk, couldn't firms that are active in the trading of vital commodities also be included in this scheme to monitor? Certainly through the GFMA, a bank lobby group, there is the view that if bank commodity trading is a systemic risk, the same logic may also be applied to other firms who are not banks but are deeply involved in commodity intermediation. 

The question is actually complex. Do trading houses which may extend credit to producers and offer  risk mitigation services act like shadow banks and thus should be included in a systemic risk analysis?  

These trading houses are facing their own set of return compression and competitive pressures. The issue is whether their logistical services with moving commodities around the world are such that they require more government oversight. I think the question should be discussed and it is worth studying these market dynamics, but where do systemic risks end? What about the fact that a lot of key commodity producers are state-owned enterprises?

There are gong to be some big changes in commodity markets given the large sell-off in many markets. Governments and consumers also have a strong dislike for speculation. These issues may com to a head in 2014 and the results cannot be predicted.