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Comment for Proposed Rule 75 FR 80747

  • From: Mary Anne Callaghan
    Organization(s):
    Mary Anne Callaghan

    Comment No: 35153
    Date: 2/18/2011

    Comment Text:

    Submitter Info:
    First Name: Mary Anne
    Last Name: Callaghan
    Mailing Address: 310 NE 85th ST
    City: Seattle
    Country: United States
    State or Province: WA
    Postal Code: 98115
    Organization Name: Mary Anne Callaghan

    Dear Chairman Gensler:

    Re: End-User Exception to Mandatory Clearing of Swaps (RIN 3038-AD10)

    My son works in the financial industry. From talking with him throughout the financial crisis, it's obvious that some areas need monitoring. Otherwise greed gets in the way of civic concern.

    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!

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