Comment Text:
Submitter Info:
First Name: Mary Anne
Last Name: Callaghan
Mailing Address: 310 NE 85th ST
City: Seattle
Country: United States
State or Province: WA
Postal Code: 98115
Organization Name: Mary Anne Callaghan
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
My son works in the financial industry. From talking with him throughout the financial crisis, it's obvious that some areas need monitoring. Otherwise greed gets in the way of civic concern.
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.
Thank you!
