Comment Text:
Submitter Info:
First Name: Dan
Last Name: Fast
Mailing Address: 33-68 21st Street
City: L.I.C.
Country: United States
State or Province: NY
Postal Code: 11106
Organization Name: NCGI
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
The big banks and their allies are pushing for changes in the transparency requirements of Dodd-Frank that would throw important trades back into the shadows. Specifically, they are calling for exemptions for a very broad array of companies from the clearing and margin requirements of the act.
Dodd-Frank already contains an exception for legitimate end-users, such as airlines and farmers, who are doing commercial hedging as part of their business from clearing and exchange trading requirements.
We must not broaden this narrow, commonsense exception to include financial and commercial institutions that want to gamble in the derivatives markets. Doing so would allow systemically important companies to enter into risky trades in a market with zero transparency and accountability.
This is exactly the kind of murky shadow banking that led to the meltdown - as every objective observer of our present financial situation well knows. Please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rulemaking process.
If you allow the banks essentially the same unfettered greed that put the world into our present mess, you will be part of the reason that the system will collapse again, with the same catastrophic results. don't be part of the problem; be part of the solution.
