Comment Text:
While I have not read the details of the rule and thus have no specific comments, I do want to make a statement of the importance of these rule and the need for it to be written tightly -- with few exemptions.
While companies will argue it will interfere with their business models, in fact, fluctuations in value of proprietary positions are more prone to do so (by causing stress on their capital. MF Global obviously was an extreme case of this.
I have been involved in the financial industry for 31 years including head of international fixed income for a major investment firm, market-maker in S&P Case-Shiller futures on the Chicago Mercantile Exchange and President of the Society of Quantitative Analysts.
