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Comment for Proposed Rule 77 FR 41213

  • From: Ellen E Barfield

    Comment No: 58628
    Date: 8/27/2012

    Comment Text:

    “I am Ellen Barfield, and my family and I were very fortunate to be minimally affected by the financial crisis. We are retired and have paid off our house, so we neither lost jobs nor a home. But we live on a fixed retirement income, and economic difficulties diminish the value of that income. 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.

    The $700 trillion global derivatives market needs effective global oversight as a key to meaningful reform. Because this market is unavoidably, inherently, global, risks are 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 you have left multiple loopholes in the proposal that very likely would 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 they are not regulated everywhere, we can’t regulate them anywhere. Please strengthen this guidance so that new Dodd-Frank derivatives protections will directly apply to the full global activities of all participants in the U.S. derivatives markets.

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