Comment Text:
Submitter Info:
First Name: Merry
Last Name: Guben
Mailing Address: 8613 Lykens Lane
City: Philadelphia
Country: United States
State or Province: Pennsylvania
Postal Code: 19128
Dear Chairman Gensler:
Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)
Unfortunately, we live in a society in which integrity and reasonableness are not natural parts of business models. They must be regulated and enforced into being by governmental authorities. We cannot rely on a "handshake" tradition, presuming that businesses will act in their own - or anyone else's - best interest.
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!
