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Comment for Proposed Rule 77 FR 41213

  • From: Ronald R Cushing
    Organization(s):
    Rocky Mtn Research 501(c)3

    Comment No: 58689
    Date: 8/27/2012

    Comment Text:

    Dear Regulators,


    “I am Ronald Cushing, and I am astonished that you do not have tighter regulations on traders.Trade gambles almost brought down the world economy and we are all still suffering from the bad players who were not regulated! Please do your job, and regulate these gamblers so they can't affect us innocent people.

    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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