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Comment for Proposed Rule 75 FR 80747

  • From: Richard Berlin
    Organization(s):
    Self

    Comment No: 34872
    Date: 2/18/2011

    Comment Text:

    Submitter Info:
    First Name: Richard
    Last Name: Berlin
    Mailing Address: 1503 Patio Dr
    City: Campbell
    Country: United States
    Postal Code: 95008
    Organization Name: Self

    Dodd-Frank already contains an exception from clearing requirements for legitimate end-users who are doing commercial hedging as part of their business.

    This narrow, commonsense exception is there to allow businesses which are inherently exposed to commodity prices (farmers, airlines, food manufacturers). It would be beyond foolish to include financial and commercial institutions in this exception. Doing so would allow systemically important companies to enter into risky trades while avoiding transparency and accountability--exactly the kind of murky shadow banking that led to the previous meltdown. Rather than helping to stabilize the system--a proper use of hedging--broadening this exception would destabilize it once again.

    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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