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Comment for Proposed Rule 77 FR 41213

  • From: Alice Batcher
    Organization(s):

    Comment No: 58664
    Date: 8/27/2012

    Comment Text:

    “I am Rev. Alice Batcher and here is how my family and I were affected by the financial crisis. Our retirement accounts were severely impacted, and are still struggling to come out ahead of where we were in 2007. Also, I have had difficulty finding work that pays my living expenses ever since this crisis began. 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.

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