Comment Text:
My name is Jennifer Teschner. I am a resident of Toledo, Ohio and have worked for fair lending practices since 1977. I want to offer my support to the comments offered by the Americans for Financial Reform.
Effective oversight of the $700 trillion global derivatives market is essential to meaningful reform. Because the market is inherently global, risks can be transferred around the world with the touch of a button. The proposed guidance you have issued on cross-border application of Dobb-Frank derivative rules is a commendable start but the proposal contains multiple loopholes what could allow foreign affiliates of Wall Street Banks to escape regulation. Big U.S. banks and other major U.S derivatives users are global corporations with hundreds if not thousands of foreign affiliates. If we don't regulate them everywhere, we can't regulate them anywhere. Please make this guidance stronger to ensure that new Dodd-Frank derivatives protections will directly apply to the full global activities of all important participants in the U.S. derivatives markets.
Thank you for your consideration and all your hard work.
Best Wishes,
Jen Teschner
