Comment Text:
The Honorable Timothy G. Massad, Chairman
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
202-418-5000
202-418-5521, fax
202-418-5514, TTY
E-mail: http://comments.cftc.gov/PublicComments/ReleasesWithComments.aspx
Re: CFTC Cuts Swaps Dealers Too Much Slack
Dear Chairman:
The Commodity Futures Trading Commission has again extended the exemption from a range of derivatives reporting rules for foreign banks active in the U.S, market.
I am disappointed at the continuing extension of exemptions from swaps reporting for foreign dealers active in the U.S. markets. Some of the transactions to which this relief applies, such as transactions with supposedly non-guaranteed affiliates of U.S. banks, could be highly relevant to derivatives risks within the U.S. economy. (As previously argued, major foreign affiliates of U.S. banks qualify for classification as “non-guaranteed” under current CFTC rules.) If foreign jurisdictions are unable to complete swaps reporting rules that satisfy U.S. standards, the U.S. must take action to force the clear reporting of derivatives risks that are connected to the U.S. financial system.
Thank you for the opportunity to bring these remarks to your attention.
Yours sincerely,
Robert E. Rutkowski
cc:
House Democratic Whip Office
2527 Faxon Court
Topeka, Kansas 66605-2086
P/F: 1 785 379-9671
E-mail: [email protected]
