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Comment for Proposed Rule 75 FR 80747

  • From: Mark Benson
    Organization(s):
    Mark Benson

    Comment No: 34321
    Date: 2/19/2011

    Comment Text:

    Submitter Info:
    First Name: Mark
    Last Name: Benson
    Mailing Address: 230 Cross Creek Court
    City: Chester
    Country: United States
    State or Province: ME
    Postal Code: 21619
    Organization Name: Mark Benson

    Dear Chairman Gensler:

    Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)

    The big banks and their allies are pushing for changes in the transparency requirements of Dodd-Frank that would throw important trades back into the shadows. Specifically, they are calling for exemptions for a very broad array of companies from the clearing and margin requirements of the act. It takes a lot of nerve to be asking for the new banking laws to be gutted after the crisis that a lack of financial regulation has caused to our economy. But apparently big banks are totally without shame, especially when it comes to making a fast buck at the expense of the rest of the country.

    Dodd-Frank already contains an exception for legitimate end-users, such as airlines and farmers, who are doing commercial hedging as part of their business from clearing and exchange trading requirements.

    We must not broaden this narrow, commonsense exception to include financial and commercial institutions that want to gamble in the derivatives markets. Doing so would allow systemically important companies to enter into risky trades in a market with zero transparency and accountability.

    This is exactly the kind of murky shadow banking that led to the meltdown - as every objective observer of our present financial situation well knows. I for one am fed up with the unwarranted power banks have over our economy which due to inadequate rules and oversight lead to the meldown we're still struggling to climb back from. Countries such as Canada and Australia never experienced a major financial meltdown in either their financial or real estate sectors as happened in the U.S. precisely because their banks are adquately regulated. Please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rulemaking process.

    Thank you!

    Thanks for your help!

    Americans for Financial Reform

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