Comment for Proposed Rule 75 FR 80747
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From:
William Montgomery
Organization(s):
William Montgomery
Comment No:
35086
Date:
2/18/2011
Comment Text:
Submitter Info:
First Name: William
Last Name: Montgomery
Mailing Address: 124 Lindley Ln
City: Pottstown
Country: United States
State or Province: PA
Postal Code: 19465
Organization Name: William Montgomery
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
Certain changes in the transparency requirements of Dodd-Frank are being sought that would throw important trades back into the shadows. Specifically, the proposed changes call for exemptions for a very broad array of companies from the clearing and margin requirements of the act.
Dodd-Frank already contains an exception from clearing and exchange trading requirements for legitimate end-users, such as airlines and farmers, who are doing commercial hedging as part of their business.
We must not broaden this narrow, common-sense 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!
