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Comment for Proposed Rule 75 FR 80747

  • From: Carol Bacher
    Organization(s):
    N/A

    Comment No: 34801
    Date: 2/18/2011

    Comment Text:

    Submitter Info:
    First Name: Carol
    Last Name: Bacher
    Mailing Address: 2415 Van Ness Ave. #202
    City: San Francisco
    Country: United States
    State or Province: CA
    Postal Code: 94109
    Organization Name: N/A

    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.

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