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Public Comments on Antidisruptive Practices Authority Contained in Dodd-Frank Wall Street Reform and Consumer Protection Act:========
Title: Antidisruptive Practices Authority Contained in Dodd-Frank Wall Street Reform and Consumer Protection Act
FR Document Number: 2010-27547
Legacy Document ID:
RIN: null
Publish Date: Tue Nov 02 00:00:00 EDT 2010
Submitter Info:
first_name David S.
last_name Nichols
address1 5107 NE Couch Street
city Portland
country United States
us_state
zip 97213
company Americans for Financial Reform
RE: Docket ID: FSOC-2010-0002 ? Public Input for the Study Regarding the Implementation of the Prohibition on Proprietary Trading and Certain Relationships With Hedge Funds and Private Equity Funds.
Dear Members of the Financial Stability Oversight Council:
I am writing as a concerned member of the American public who was affected by the financial meltdown and bailouts caused by Wall Street banks? high-risk trading. I am submitting this comment pursuant to the Financial Stability Oversight Council?s (FSOC) request for comment on Sections 619-621 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Banks should be in the business of lending to America?s small businesses and families, not using our money to run a private casino where the House always wins. We never again want to be left on the hook for the bad bets Wall Street.
Question: 4/9
We demand a strong Volcker Rule that:
Doesn?t Let the Exceptions Swallow the Rule: Bankers and their lobbyists are already looking for ways to make narrow exceptions (like those for ?market-making activities? and ?risk-mitigating hedging?) into massive loopholes to maintain business as usual. If banks are profiting from swings in price, that?s proprietary trading. If the hedging trade is itself a high-risk investment, that should be prohibited, too.
Question: 7
We demand a strong Volcker Rule that:
Doesn?t Let Banks Bail Out Hedge Funds: Even though the Rule drastically limits banks? involvement in risky buyout funds, it doesn?t end it completely. We know that even a small bank investment in these risky funds can lead to a big bank bailout that puts the system at risk: Bear Stearns ended up spending $3 billion bailing out a hedge fund it only had $35 million invested in ? because it didn?t want to look bad. Regulators must write the anti-bailout provisions so they?re air-tight ? and force banks to warn anyone who does hedge fund business with them that they won?t be able to bail them out
Question: 12
We demand a strong Volcker Rule that:
Doesn?t Let Banks Cheat Their Customers: The Volcker Rule bans certain specific conflicts of interest outright (such as when Goldman Sachs bet against the asset-backed securities they packaged to fail and sold to their clients), but it also has a catch-all rule: regulators must ban any activity that creates a material conflict of interest between banks and their customers. Regulators should investigate the full range of ways that Wall Street insiders are profiting at the expense of the rest of us, and use this new power to crack down on abuses.
Thank you for your consideration of my views.
Sincerely,
David S. Nichols
