Comment Text:
My name is Neal Elinoff and here is how my family and I were affected by the financial crisis.
I had to file a personal Chapter 11 bankruptcy, and that was after I dealt with hundreds of hours and two years of trying to get loan modifications that were not even designed for homeowners. they were designed to soften the landing of the banks! My bankruptcy plan still has not been approved, and it's been over 2 years!
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.
