Comment Text:
From: Ken Marsh
Sent: Tuesday, February 15, 2011 10:43 AM
To: questions
Subject: End-User Exception in RIN 3038-AD10?
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Dear Chairman Gensler, Commodity Futures Trading Commission:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
Why are 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, aren't they calling for exemptions for a very broad array of companies from the clearing and margin requirements of the act?
Doesn't Dodd-Frank already contain 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?
Why must we broaden this narrow, commonsense exception to include financial and commercial institutions that want to gamble in the derivatives markets? Wouldn't doing so allow systemically important companies to enter into risky trades in a market with zero transparency and accountability?
Wouldn't this lead exactly to the same the kind of murky shadow banking that led to the meltdown - as every objective observer of our present financial situation well knows.?
Will you please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rulemaking process?
Ken Marsh
2435 Corinth Ave
Los Angeles, CA 90064
