Subject: File No. S7-41-11
From: Robina Quale-Leach

February 10, 2012


I’m writing in support of a strong Volcker Rule. The economic collapse of 2008 came very close to closing down my son's and daughter-in-law's educational nonprofit, Raven Hill Discovery Center (located on 140 brook-to-high-hilltop acres in Northwest Lower Michigan) where schoolchildren come on school-organized field trips so that they can be shown the differences between seven ecological zones by two certified biology teachers. 

Why?  Because tax revenues went down so rapidly and greatly with the collapse of property values that they had to turn to local foundations, parent-teacher organizations, and other community groups to enable schools to transport their students to Raven Hill.  Even with this support (which brought in less to keep the Center going than the previous tax-revenue-provided payments had done), they still had to let their two part-time employees go, and rely entirely on area volunteers.  This means that they have been unable to return to anything like the number of field trips they can accept each  day, even though their private support has slightly more than kept up with inflation.

This has been and still remains a real blow to every school science program in Northwest Lower Michigan. 

And it should never have happened in the first place.

As you prepare the final rule, bear in mind the fundamental goal of the rule – to ban big banks from exposing consumers and taxpayers to risky proprietary trades.

Banks that break the rule should face swift, automatic penalties for violations. Violations of the Volcker Rule endanger the stability of our financial system. They should not be treated lightly.  They betray our entire nation when they do so.

Exemptions should only be allowed if they do not undermine this goal. If an exemption would result in exposing consumers and taxpayers to bank risk, it should be categorically and immediately rejected.

Thank you for considering my comment,

Robina Quale-Leach

Albion, MI