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Comment for Proposed Rule 75 FR 80747

  • From: Tim Sullivan
    Organization(s):

    Comment No: 35217
    Date: 2/18/2011

    Comment Text:

    Submitter Info:
    First Name: Tim
    Last Name: Sullivan
    Mailing Address: 28 Robin Dr
    City: Bakhamsted r
    Country: United States
    State or Province: CT
    Postal Code: 06063


    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.

    Without transparency and regulatory oversight real market value or obligation cannot be determined. The consequences to the taxpayers and citizens have been made shockingly clear. Trading on margin in any instrument is a nonproductive gamble as far as using capital is concerned. Please demonstrate that the colossal mistakes made will not be repeated.

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