Comment Text:
Submitter Info:
First Name: Sarah
City: Alamogordo
Country: United States
State or Province: NM
Organization Name: Sarah
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
The changes in the transparency requirements of Dodd-Frank that would throw important trades back into the shadows. Specifically the 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.
Narrow exceptions make sense, but to include financial and commercial institutions that want to gamble in the derivatives markets 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. Please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rulemaking process.
Thank you!