Comment Text:
Dear Mr. Stawick
Sarah H. Zimmerman
3290 Ridgerock Way
Snellville, GA 30078
Mr. David A. Stawick
Secretary
Commodity Futures Trading Commission
Three Lafayette Center 1155 21st Street, NW
Washington, DC 20581
Re: Considerations to best implement Dodd-Frank Wall Street Reform Act
Dear Mr. Stawick:
Please do not discard this email because it is being sent en masse by many of us who want to strengthen the Dodd-Frank financial reform law to protect American citizens and people around the world. I have included a personal message at the end of the email voicing my own concerns.
While developing the rules to implement the Dodd-Frank financial reform law, it is important that the CFTC do everything possible to maintain the strong spirit of that law. After years of highly volatile commodity markets, the CFTC has an important opportunity to bring order back to these important markets by limiting excessive speculation. I suggest five important points to consider:
1. Definition of “commercial risk”
I believe it is important to adhere to the spirit of the Dodd-Frank bill and limit this definition to bona fide users of commodity markets who deal with physical commodities. Commercial risk should not be expanded to include financial risks for banks and hedge funds.
2. Position limits
The financial reform law clearly states that the Commission shall set position limits to diminish, eliminate or prevent ‘excessive speculation.’ I urge the Commission to define limits that will address not only manipulation, but also excessive speculation, which will require a stricter approach.
3. Exchange traded notes and funds and swap-based index funds
I am especially concerned about the influence of these instruments on commodity markets and ask the Commission to define more aggressive limits for these types of speculative instruments.
Ownership of trading facilities
According to a statement by the Office of the Comptroller of the Currency, the five largest banks currently control 96 percent of derivatives activity. It is important to prevent these or any other class of business from collectively owning majority stakes in clearinghouses and other trading facilities. The CFTC must establish both a meaningful limit on individual ownership and a limit on collective ownership if the proposed rule is to have the intended effect of limiting conflicts of interest, assuring transparency and open competition, and preventing clearinghouses and exchanges from catering solely to the interests of a few large participants in the financial community.
High frequency trading
Computerized/algorithm-based trading, including high-frequency trading appears to have a growing effect on commodity markets, so I support the Commission carrying out in-depth studies of their effects, and considering the appropriateness of these types of investments in important commodity markets at all.
The previous portion of this letter was written for me by those who are far more knowledgeable about the law and the machinations of the financial industry. However, I must speak personally about this issue as well. If political organizations took the time to canvass working middle and lower class Americans, they would discover that the vast majority who are struggling to survive are appalled at the greed and selfishness of those who invest to create bubbles that earn huge (and for us, unimaginable) amounts of money while harming the lower and middle classes and, above all, the poor, not only in this country, but around the world as well.
We feel as if there is no one to speak for us, even though our numbers undoubtedly surpass the chosen few who can play with money and our lives. The advocacy group that is sponsoring this email campaign is trying to speak for ordinary citizens and the poor around the world who will continue to suffer while wealthy, greedy, basically inhumane investors continue to make more money than they can ever use.
Many of us have already been hurt financially by the housing bubble, even though we did not purchase overpriced homes. Our home has lost value in past 2-3 years because a few homes in our neighborhood have gone into foreclosure. There is absolutely nothing that we can do about this now, and there is no way we could have foreseen this crisis. We are at retirement age, but may never be able to retire or move to a more desirable location because of the actions of these financial gamblers. Incidentally, my husband and I have taught/coached in public schools for nearly 60 total years, so we have devoted our lives to serving people and our country.
Please, please do not let these moneyed individuals and organizations cause any further pain to the average American citizen with their arrogant, foolish, and completely selfish manipulation of our economy and world markets. Please know that there are millions upon millions of people just like me who have no voice--and be the voice who speaks for us.
Thank you for your consideration,
Sincerely,
Sarah H. Zimmerman
Sarah Zimmerman
3290 Ridgerock Way
Snellville, GA 30078
US
