Comment Text:
Submitter Info:
First Name: Jane
Last Name: Harrison
Mailing Address: 484 Orchard Cove Rd
City: Waynesville
Country: United States
State or Province: NC
Postal Code: 28785
Organization Name: Jane Harrison
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.
If these kinds trades are as good for everybody as the big banks would have us believe, then transparency and accountability should not be a problem. If they really have to occur in the shadows, that tells me that it is really a booky scheme that is rigged by insiders and should not be allowed at all.
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.
Thank you!
