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  • Comment Detail

  • Date: 09/09/14
    First Name: Ben
    Last Name: Morrison
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA45

  • Comment

    Margin and Capital Requirements for Covered Swap Entities

    Dodd Frank does not give regulators expressed or implied authority to set margin and capital requirements to end users. Applying these requirements in this proposed rule gives an advantage in foreign markets and does not provide protection from systemic risk. Applying rules to America and not to the rest of the world only hurts Americans. All that will be accomplished with this proposed rule is a decline in the performance of the American economy due to over regulation. We will still be subject to systemic risks, because many of those risks do not reside in the United States of America. US regulators have no authority to regulate the marketplace outside of the US, and have no authority to regulate the US Market in this manner.