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Comment for Proposed Rule 77 FR 41213

  • From: Sally Small

    Comment No: 58656
    Date: 8/27/2012

    Comment Text:

    My family and I were affected by the financial crisis when my husband was laid off during a downsizing immediately after the financial crash in the fall of 2008. Both my husband and I were unemployeed for about about a year before we found new permanent jobs. Just today I learned that my brother-in-law was downsized this past week. He has two sons dependent upon his support. 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. We must stop allowing King Midas-type behavior, lest we as a nation end up like King Midas's daughter - destroyed - and llike King Midas himself - realizing too late the folly of his pursuit of more and more wealth.

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