Subject: File No. S7-40-10
From: Natalie P. Wagner Willis
Affiliation: Owner/Founder of VitalFinancialsLLC

September 30, 2011

It is absolutely imparative that Dodd-Frank be modified to allow the Congolese people to create their own infastructure with their own natural resources Innocent people will be held back in an extreme poverty, affecting their most basic phylical safety, if the Dodd-Frank law is allowed to go through as it. Unlawful people will always exist. Although it is importatnt for the U.S. to do what it can to stay away from such unscrupulous actvity, preventing innocent people from creating a safe and prosperous lives for themselves is not an appropriate cost.

As put by Chuck Blakeman:

Dear Sirs:

A company in the United States that is co-owned by Chuck Blakeman, an American social entrepreneur, and a Congolese tribal Chief, has committed to create sustainable economies in the Congo by exporting minerals and leaving a significant portion of the profits local, something no other company has ever done. They also will build potable water projects, clinics, and schools with the profits, and create training certifications for local business owners to learn how to run businesses.
They will also fund these businesses and believe they can solve systemic poverty in the DR Congo in 5-10 years.

But now an obscure provision tucked into the Dodd-Frank Act could be jeopardizing much of this and is already hurting hundreds of thousands of Congolese and putting some in immediate danger of death.

The Problem The Dodd-Frank Act Provision 1502
The recent Dodd-Frank Act has had a terrible affect in the Congo. A provision (1502) in the bill requires all companies in America to disclose if their products use minerals from the Congo, and to create a trail of paperwork and outside audits to prove they did not create profits for criminal militias. As a result of the unintended stigma this has created, the mineral trade for central Africa has evaporated in the last few weeks, creating an effective mineral embargo of the entire region. Thousands are being devastated by Dodd-Frank.

The Negative Effect
Chucks private company has been lauded by Chiefs throughout the Congo for our commitment to export minerals above board and for our desire to build local potable water projects, clinics and schools.

Because of the stigma surrounding Dodd-Frank, only the Criminals are benefiting now.

One tribe dug and stored tons of coltan over the last two years without pay simply because they did not want to sell it to war lords. Chuck was supposed to meet these chiefs in Africa next week to export the first of a 20 year contract for monthly shipments. But because of the stigma attached to Dodd-Frank, no buyers can be found, leaving starvation or criminalized sales as the options for these chiefs. The 20 year contract would create job stability with certain futures for people who have never had it.

The Nuclear Option is Not Acceptable
Our company was stepping into the legitimacy gap, but the U.S. government and very well-meaning activists have created what we see as a nuclear option.

The Main Argument Against Dodd-Frank The Nuclear Option Is Not Acceptable