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Comment for Proposed Rule 77 FR 28819

  • From: Susan Seltzer
    The Derivative Project

    Comment No: 58225
    Date: 5/29/2012

    Comment Text:

    The attached response to the Volcker Rule was prepared February 23, 2012 and the request for a cost-benefit analysis was submitted to the House Financial Services on February 23, 2012, with the intent of not having to submit the attached comments to the CFTC. The House Financial Services Committee refused to discuss and/or respond this proposal since The Derivative Project also has a non-partisan Blog.

    We respectfully request the CFTC and the SEC, given ongoing material speculative trades by major commercial banks, take a fresh look at the role of Over-the-Counter markets on behalf of every U.S. taxpayer. To ensure fair and orderly capital markets for every end user, including America's farmers, (1) credit default swaps must be moved to regulated exchanges and (2) farmers need comparable access to capital markets, without daily mark to market, as America's importers and exporters have in the current OTC foreign exchange markets.

    The playing field must be even for every business and all material speculation must be moved to futures exchanges.

    The events that have happened since Dodd Frank was passed in Summer 2010 have rendered the framework for this legislation obsolete. It is time for a fresh approach for rule making that considers the cost-benefits to the U.S. taxpayer, nor longer the exclusive focus on Wall Street's profit model.

    Attached are proposed avenues for change for the over-the-counter markets and organized futures exchanges, to render fair and orderly capital markets for every participant submitted today for CFTC debate at you Public Hearing on May 31, 2012.

    Thank you for accepting these comments.


    Susan Seltzer
    The Derivative Project