Subject: OCC: OCC-2011-14, FRS: Docket No. R-1432 and RIN 7100 AD82, FDIC: RIN 3064-AD85, SEC: S7-41-11

February 13, 2012

To Whom it May Concern,

I urge you to enact a strong "Volcker Rule" pursuant to the Dodd-Frank bill. Banks are given the extraordinarily privilege of a taxpayer backstop, because they are part of the infrastructure of the economy. The flip side is that they must be forced to adopt a conservative, minimally risky business model more akin to a utility than a hedge fund. The banks are arguing, cynically and selfishly, that they ought to both enjoy that FDIC backstop and be able to take the large risks that result in high yields. This is self-contradictory, and the financial regulators must dispense with this argument, and instead write a strong "Volcker Rule" for the Dodd-Frank Act that truly separates proprietary trading from the provision of a financial infrastructure for our economy.

We need you to write a final rule that accomplishes the fundamental goals of the law: separating risky proprietary trading from the traditional business functions of banking institutions, banning proprietary trading at "too big to fail" banks, reducing the risk that financial market gambles present to the safety of our whole financial system, and stopping conflicts of interest like those that saw Wall Street firms selling their customers deals they had designed to fail.

It is important to not let the rule be undermined by exemptions or exceptions. The Dodd Frank Act instructs you to make sure that the activities big banks are permitted to engage in do not create the risk of another financial crisis. Accomplishing this requires changes to current business practices on Wall Street. I urge you not to be swayed by financial industry interest in protecting a status quo that has benefited them and put the rest of us at risk.

It is also important that banks that break the rules should face real penalties for violations. Violations of the "Volcker Rule" will endanger the stability of our financial system. They should not be treated lightly.

Thank you for considering my views.


Jim Steitz