Comment Text:
Submitter Info:
First Name: Lisa
Last Name: Gagnon
Mailing Address: 170 Highland Circle
City: Blue Ridge
Country: United States
State or Province: GA
Postal Code: 30513
Organization Name: Lisa Gagnon
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
Big banks and their allies are pushing for changes in the transparency requirements of Dodd-Frank that would throw important trades back into obscurity. Specifically, they are calling for exemptions for a very broad array of companies from the clearing and margin requirements of the act, designed to offer some sort of transparency.
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.
Please do 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. We don't need any more loopholes!
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. Please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rule-making process.
Thank you!
