Subject: File No. S7-40-10
From: Charles Blakeman
Affiliation: Business Advisory

October 9, 2011

Our Congo-based company works with Congolese tribes to help them export without a dime going to conflict groups. Dodd-Frank has been disastrous for them.

I challenge the supporters to take a poll of those they are supposedly trying to protect. The response would tell them that, while Dodd-Frank was well-meaning, it is an unmitigated disaster in practice. COCABI, COMIMPA and COMIDER represent 20,000 miners in the conflict area. They all say theyve never even been contacted.

There are six regions from which Dodd-Frank minerals are mined, and only one of them has ever had anything to do with conflict. Dodd-Frank has put them all out of business before it is even enacted. The World Bank says it has negatively affected 10 million Congolese.

I was in Tanzania last week to help a chief export his coltan using a visible, well-documented process that ensures not a dime goes to conflict. His people will go hungry because the smelters, citing Dodd-Frank, have vanished. The chief is devastated, as are the millions who find their meager livelihoods destroyed by this over-reaching act.

The issue with Dodd-Frank is that it is a nuclear option that demonizes minerals instead of criminals. Its no different than burning down every house in town to stop a burglar from stealing, who will simply steal from somewhere else. Ludicrous.

Dodd-Frank has burned down the entire mining industry in the Congo in hopes that their scorched earth policy will catch a militia group in its path. They are willing to take down every innocent man, woman, and child who live off mining. Such massive collateral damage is not acceptable under any circumstance.

Remove mining from the equation and the militia will exact its pound of flesh from the locals by other means. This should be handled by targeting militias, not mining. Dodd-Frank takes the route of universal collateral damage, which, before the bill is enacted, has already destroyed the livelihoods of the innocents who depend on it.

Unconscionable.

You MUST stop this provision from being enacted. It is killing the very people it was supposed to protect. You cannot go forward with this without the blood of the innocents on your hands.