Comment Text:
Please do not delay implementation of the new regulatory framework for swaps mandated by the Dodd-Frank Act. Financial institutions with undue influence and resources have, in fact, been gambling on (and driving up) the prices of core commodities that the vast majority of our society requires for day to day subsistence. Though this gambling has been specially permitted through various state and federal exemptions, it is still gambling and is easily characterized by a single word: unfair. If your commission would please just find a way to consider the word "fair" with each ruling you make, it would benefit us all.
There is no real need for a modified schedule of moving to the new swaps compliance regime. Such a delay would only benefit the profits of a few interest groups at the expense of true users and the general public. A look at the comments to 17 CFR Parts 37, 38, and 39 that your office referenced are clearly weighted towards large commercial and/or financial organizations with interests essentially in opposition to the interests of a much greater number of consumers and citizens (*8 Letter from the Coalition of Physical Energy, Companies; *9 Letter from the Futures Industry Association, the Financial Services Forum, the International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association; *10 Letter from the Bank of Tokyo-Mitsubishi UFJ; *11 Letter from the Financial Services Roundtable).
In general, all swaps should be subject to mandatory clearing. If any swap involving a financial institution is permitted to be end-user exempted, the result will be a large, and unfair, loophole. A true look at fairness in US and world markets would clearly show that the fairest action would be to repeal the Commodity Futures Modernization Act of 2000. Understanding that that will not happen, probably most due to industry lobbying, mitigating the act by implementing the new Dodd-Frank Act framework is even more essential.
As a concerned and directly affected citizen, I beg you as my government representatives to NOT delay implementation of this critical rule set.
Sincerely,
Lorenz Glaser
