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No Offshore End-Run Around Derivatives Reform

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No Offshore End-Run Around Derivatives Reform No Offshore End-Run Around Derivatives Reform To the Commissioners of the Commodity Futures Trading Commission: We, the undersigned, urge you to stand up for rules that apply the transparency and safety requirements of the Dodd-Frank Act to all derivatives transactions relevant to U.S. markets, regardless of whether these transactions are routed through a foreign subsidiary or entity. We need rules that cover all transactions, wherever they occur, which have the potential to jeopardize America’s financial institutions and financial security. That’s how the rules must to be structured in order to work.. And that’s how Dodd-Frank was written. We call on you to uphold that standard. Exempting the transactions of overseas subsidiaries from the full scope of derivatives regulation would be a giant loophole, encouraging banks to move transactions offshore and permitting an indefinite continuation of the kind of reckless activity that helped crash the economy in 2008. Delay, too, can be a strategy for weakening and evading the law. Four years after the financial crisis and two years after the passage of Dodd Frank, it is time to insist on high standards that apply to all the derivatives transactions of U.S. banks and their subsidiaries. David Montano, Denver, CO Joan Kramer, Los Angeles, CA Lily Kirsanow, Rio Rancho, NM Molly Noone, Chandler, AZ Bradley Walker, Arlington, TX Jocelyn Davis-Beck, Beecher, IL Kevin Cox, San Francisco, CA John Flitcraft, Cambria, CA Nancy Rominger, Salisbury, NC Sandra Holt, Casselberry, FL melvin olson, flippin, AR Karen Christian, Vail, AZ Stephen Hackney, Grangeville, ID Ron Bigler, Silver Spring, MD Erika Ingato, Zionsville, PA Carla Behrens, Longmont, CO Jeni Bettjer, Descanso, CA Karin Paris, Ennis, TX Ms. Stacey A. Ward, Esq., Los Lunas, NM Jan Stevenson, Stillwater, OK Philip Lohrmann, Battle Ground, WA Donald J. Shaw, SYRACUSE, NY Catharina Howard, San Leandro, CA Dena Wise, Knoxville, TN John Garza, Huntington Beach, CA Ameire Stevens, Detroit, MI Ellen Garnett, Chapin, SC Linda Brown, Phoenix, AZ Robert Rogan, Detroit, MI Robert J. Hayes, Lawrenceburg, TN Ken Burke, Oakland, CA chuck matzker, Framingham, MA Don Brake, Holland, MI Arthur Hansen, Kew Gardens Hills, NY Richard Bolotin, Arlington, VA bruce tonnessen, deerfield beach, FL Lionel Castille, New Orleans, LA Alan Wojtalik, Baltimore, MD Ted Fishman, , Richard Duffy, Yonkers, NY James Alstrum, Normal, IL Lawrence Meany, Waltham, MA Sawatdee Sanlavun, silver spring, MD Gaye Smith, Los Angeles, CA Velma Andregg, Tulsa, OK David Greene, Columbus, OH Dan Meier, Cedar Falls, IA DOUGLAS GILMORE, nashvile, TN Mary Coleman, Orangevale, CA Barbara Juszkiewicz, Buffalo, NY Michael Harriosn, Eckert, CO Andres Mejides, Homestead, FL Barbara Kaye-May, Corning, CA Joseph Silva, Lincoln, CA Dean Robb, Plainfield, NJ james wayrynen, entiat, WA Andrew Janson, Pasadena, CA Elizabeth Saenger, Mamaroneck, NY DONALD WATSON, MONROVIA, MD david sorkin, new york, NY James Moran, Reston, VA Stosh Zona, Avondale, PA Anita Gebhardt, Dallas, TX Sally Small, Columbus, OH Emily Willoughby, Tukwila, WA Michelle Mullen, Lincoln, NE Joan Reilly, Philadelphia, PA John M Persel, Toms River, NJ Shane McAndrew, Prospect Park, PA Mark Lamport, Marion, IN Timothy Taylor, Los Angeles, CA Joanne Zipay, New Windsor, NY Bill and Jan Tache, Penn Valley, CA Donald Allred, Ellensburg, WA Colleen Carter, Canyon Country, CA Karen Thompson, Richmond, CA Anthony Capobianco, Bethel Park, PA David Reid, Colorado Springs, CO Jeanne Piehl, hutchinson, MN Patricia Fleetwood, Nashville, IN Elizabeth Guise, Los Angeles, CA Robert Cassidy, Harrison, ME Susan Pelakh, Cocoa Beach, FL Rebecca Tippens, Colrain, MA Nicholas Mantas, TWP WASHINTON, NJ Richard Arrindell, Melbourne, FL michael riley, quincy, MA Daniel Fischer, Astoria, NY tony viren, machesney park, IL Jane Halsey, San Francisco, CA Harold T. Hodes, Ithaca, NY Randy Meek, Lincoln, NE Michael Molder, Newberry, SC Karen Lind, Union City, NJ Christy Kurtz, Bartlett, IL Joan Lang, Cleveland, OH Denise Brennan, Auburn Hills, MI Rachel M Hervey PHN, Santa Margarita, CA Dona LaSchiava, Tucson, AZ Rhesa Antone, Clayton, DE Donald Hyatt, Columbus, OH Gabriel Sheets, Merced, CA tara daniels, dallas, TX Stephen Bamford, Tallahassee, FL Anita McDermott, North Kingstown, RI Pam Hogarth, Los Angeles, CA John Mowrer, Myerstown, PA Ed Sahagian-Allsopp, Milwaukee, WI William Montgomery, Pottstown, PA Vivian Gilbert, Red Feather Lakes, CO Bill Moore, Seattle, WA Mitzi Duxbury, Madison, WI Donna Potter, cary, NC Mr & Mrs. Andrew and Antonia Chianis, Blue David Modarelli, Akron, OH Jay, CA Barbara Kantola, Niles, MI Mikki Chalker, Binghamton, NY Donald Crosby, Tallahassee, FL N Ray, , Gordon Brown, Topanga, CA Pamela Scott, Boulder Creek, CA Timothy Post, Lee's Summit, MO J L Cone, Ruskin, FL p ross, fairmont, WV Ramsay MacInnes, Cherry Valley, MA Shirley Crenshaw, St. Louis, MO Paul Lambert, Boynton Beach, FL Michele Hood, Tallahassee, FL L.D. Hieber Jr., Chelsea, MI Donald Ino, San Francisco, CA Deborah Rubin, New York, NY Mark Gotvald, Pleasant Hill, CA Wendy Schultz, Seinole, FL Harriet McCleary, Minneapolis, MN Tullio Giudici, Glendale, CA Sean Hagstrom, Redlands, CA Susan Morrissey, Menasha, WI Weldon Tallant, OFallon, IL Dan Carpita, Enumclaw, WA Katherine Nelson, Kent, WA Leslie Cassidy, New York, NY dora haslett, portland, OR Dana Bleckinger, Portland, OR SHIRLEY ROBINSON, Brooksville, FL DIANNE NOBLETT, MECHANICVILLE, NY Brad Walker, Swansea, IL Marilyn Booton, Saint Paul, MN Frank Heller, Duluth, MN Jesse Gennarelli, Nanuet, NY Michael McHugh, Pinellas Park, FL Garry Potts, Dallas, TX Virginia Pratt, Jamaica Plain, MA Sam Cowan, Carmichael, CA Jacquesques Zakin, Worthington, OH Judith Peter, Port Charlotte, FL Norma Fleischer, Naples, FL Melvin Greer, Glendale, AZ Jorge Garriga, Hialeah, FL Shari Bruun, Camas, WA Linda Kronholm, North Port, FL Henry Winckler, CARMEL, IN lee brown, muskegon, MI Julie Hoffer, Brooklyn, NY T C, Crest Hill, IL Bonita De Trinis, Lyndhurst, VA Brian Gregory, Bremerton, WA Allison Burke, Hemet, CA Bryan Lilienkamp, Indianapolis, IN Randy Christensen, Fort Lauderdale, FL Davis Montalvan, Whitter, CA David Burns, Louisville, CO Alyssa McConkey, Loveland, CO Pamylle Greinke, Peconic, NY Martin Mendelsohn, Norfolk, VA Anda Friedman, Cambridge, MA Den Socling, Jersey Shore, PA Michael Sherber, Avon, CT Al Knickerbocker, Mountain View, CA Keith Walsh, Brooklyn, NY Terry Huey, Lexington, KY Richard Rew, Denver, CO Paul Jefferson, Lawrence, KS mike wise, murfreesboro, TN Raymond Wells, Ellensburg, WA Michael Johnson, Ruther Glen, VA Laura Neiman, New York, NY Angel Garcia, Bronx, NY Carl Carter, Hillsboro, OR Alexandra Gruskos, Pittsburgh, PA Robin Fox, Croton-on-Hudson, NY April Atwood, Seattle, WA Kelly Warner, Bigelow, AR John Fagot, Georgetown, TX Tina Snyder, Tonopah, NV Anthony Nicolau, Brooklyn, NY Krishnan Chittur, Briarcliff Manor, NY Joyce Duarte, Middleburg, FL Kathy Bentley, Baltimore, MD Lyle Elkins, San Diego, CA Ann McMullen, Sandy, UT Chessa Rae Johnson, New Orleans, LA Giles Morris, McLean, VA Ed Pinson, Monrovia, CA Jim Thomas, Chapel Hill, NC Terry Adams, tower city, PA Richard Klene, Jackson, WY Donald Wolochow, La Jolla, CA Karla Devine, Manhattan Beach, CA John Kaufmann, Merritt Island, FL Patricia Schwab RN, San Diego, CA Libby J. Goldstein, Philadelphia, PA Vinayak Vinayak, Palm Springs, CA Rebecca Lubetkin, Mountain Lakes, NJ M. Tomec, Granger, IN Hillary Buckingham, Hastings on Hudson, NY Jay Fry, Grand Prairie, TX Cynthia RaHA, New York, NY David Miller, Huntington, NY Mary Truelove, Martinsville, IN Nicholas Mantas, Twp of Washington, NJ Dennis Moore, Salem, OR Vincent Gormley, Sioux Falls, SD Arthur Sutherland, Sandy, UT John Lockard, Summerfield, FL Graham Joy, Purcellville, VA Bill Liddle, Schenectady, NY Ron Bigler, Silver Spring, MD carleen mulloy, kansas, MO Tim Hayes, El Cajon, CA Michael Kemper, San Francisco, CA salman danish, chicago, IL Helena Freeman, LA, CA Beverly Simone, West Nyack, NY henry holtzman, new york, NY Jamie Terrill, Fort Collins, CO Carolyn Wood, Albany, GA George Campbell, Clearwater, FL Marla Drucker, Asheville, NC Jose Ricardo Bondoc, San Francisco, CA Bob Duke, Charlottesville, VA Ronald Sweeney, Cherokee, OK Ronald Richardson, Missouri Valley, IA Jose Luis Greco, Danbury, CT Mark Swenson, Maple Grove, MN Ron Dixon, Princeville, HI Celine Fatula-Grenier, Capitola, CA Sharon Rosner, Beverly Hills, CA Robert Giese, Appleton, WI Peter Gunther, Chicago, IL Tim Warner, Los Angeles, CA Jennifer Scott, Fort Myers, FL Lisa D'Ambrosio, Lancaster, MA Bob and Mary Place, Westerville, OH Gwen Schmitt, Pleasant Hill, CA d hilliard, marietta, GA Raven Dorantes, San Francisco, CA James Breymaier, Oak Park, IL Kevin Macdonald, Belgrade Lakes, ME Virginia Utt, Melbourne, FL Robert Deck, Toledo, OH Mark Hein, Woodland Hills, CA Howard Stein, Chicago, IL Temma Pistrang, Lake Forest Park, WA Glenn Whitmore, Fossil, OR John Crotty, Manchester, MO E. Schmidt, Ellisville, MO Sam Sanders, Santa Fe, NM Barry Hubbard, Atlanta, GA Richard Santora, Center Valley, PA Joseph Whittle, Sykesville, MD richard willing, terlingua, TX Laurie Smyla, Sloatsburg, NY Alese Tait, Stratford, CT Robert Fricke, Alsip, IL Janet Forst, San Francisco, CA Tom Thorpe, New Port Richey, FL Molinda Parker, Grove, OK Candace Johnson, Long Beach, CA Richard Brei, Geneseo, IL Alan Kardoff, Palm Bay, FL Judith Shipsky, Albuquerque, NM Madelyn Matijevich, Clinton, MS Megan Anderson, Fridley, MN Ardelle Tuxen, La Crosse,
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