Comment Text:
“I am Ann Lamb, and here is how my family and I were affected by the financial crisis. My daughter's house remains in foreclosure even as the usurious mortgage payments are made, with the bank and mortgage servicing company adding ever more penalties and fees to the amount (which they have never given a credible accounting for) that she owes. We bear the brunt of keeping her and her four children in their home, paying over $4000 per month for her tiny, 1927 farmhouse in a small town in California. She has declared bankruptcy. I think the derivative products that sold her mortgage--to a non-US bank-- are a scandal that someone should be accountable for. I never again want to be called on to bail out big corporations and Wall Street banks for irresponsible “heads I win, tails you lose” gambles.
Effective oversight of the $700 trillion global derivatives market is a key to meaningful reform. Because this 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 Dodd-Frank derivatives rules shows that you understand the importance of this issue. But the proposal contains multiple loopholes that 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.
