Comment Text:
Submitter Info:
First Name: Charlie
Last Name: Cooper
Mailing Address: 2359 Nutmeg Terrace
City: Baltimore
Country: United States
State or Province: MD
Postal Code: 21209
Organization Name: Generations for Peace and Democracy
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
Adam Smith: "People of the same trade seldom meet together even for merriment and diversion, but the conversation ends in a conspiracy against the public or some contrivance to raise prices."
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.
Dodd-Frank already contains an exception from clearing and exchange trading requirements for end-users, such as airlines and farmers, who are doing commercial hedging as part of their business.
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.
It's ironic that people claiming be free-market champions oppose the kind of transparency that Adam Smith and every other objective economist postulates as essential to a true free market.
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 rulemaking process.
