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Comment for Proposed Rule 75 FR 80747

  • From: Tom Glover
    Organization(s):
    Americans for Financial Reform

    Comment No: 34805
    Date: 2/18/2011

    Comment Text:

    Submitter Info:
    First Name: Tom
    Last Name: Glover
    Mailing Address: 1318 16th St South
    City: Great Falls
    Country: United States
    State or Province: MT
    Postal Code: 59405
    Organization Name: Americans for Financial Reform


    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.

    Thank you!

    Thanks for your help!

    Tom Glover, Retired Teacher

    Americans for Financial Reform

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