Comment Text:
Submitter Info:
First Name: Robert
Last Name: Weld
Mailing Address: 2234 Clifton Place
City: Hoffman Estates
Country: United States
Postal Code: 60169
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.
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. Please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rulemaking process.
Should they be given the exemptions they are requesting, they should be stripped of any FDIC deposit coverage, be required to disclose to all depositors that their accounts are no longer protected by the FDIC and be restricted from doing any business with Federal, State or Local governments so that these entities funds are not put at risk.
Additionally they should no be able to borrow money from the Federal Reserve system at preferential rates. The Federal Reserve system is not a piggy bank for gamblers to raid at will.
Thank you!
