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Comment for Proposed Rule 75 FR 80747

  • From: Jennifer Stiller
    Organization(s):
    Law Offices of Jennifer A. Stiller

    Comment No: 34856
    Date: 2/18/2011

    Comment Text:

    Submitter Info:
    First Name: Jennifer
    Last Name: Stiller
    Mailing Address: 625 Haydock Lane
    City: Haverford
    Country: United States
    State or Province: PA
    Postal Code: 19041
    Organization Name: Law Offices of Jennifer A. Stiller

    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. THEY TANKED THE ECONOMY AND GAVE MY SMALL BUSINESS TWO PROFITLESS YEARS. Please implement Dodd-Frank as written and do not give in to the pressure to weaken the legislation in the rulemaking process.

    Thank you!

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