Subject: File No. S7-12-11
From: Maneesh Pangasa

May 31, 2011

Elizabeth Murphy
100 F Street, NE
Washington, DC 20549

Dear Murphy,

America paid a terrible economic price because of irresponsible risk-taking by Wall Street executives. Those executives took those risks because they knew that they could walk away with billions of dollars in bonuses and stock options and never pay for the long-term consequences of their actions. We need tough rules so that Wall Street pay packages don't encourage short-term risk taking.

It is time to end the too big to fail system -- its outrageous that some too big to fail banks bailed out during the financial crisis are even bigger now than before the crisis. We need a return to Glass Steagall and the financial consumer and taxpayer protections of the New Deal era established during FDR's Presidency when commercial and investment banks were separate, speculation was regulated if not banned, there was sufficient competition, consumer choice in financial services market and the failure of any one bank thus could not threaten the entire system. It's time to end the Wall Street culture of heads we win, tails you lose (Main St. loses) we win. Socialism for the rich -- bailouts to protect them when they can't cover their losses is unacceptable. Bailing them out sends a message if they engage in risky behavior again and crash the economy the U.S. Government will be there to bail them out again and taxpayers will again be stuck with the tab.

The Dodd Frank Wall Street Reform bill is not perfect there were more tough financial regulations that could have and should have been added to the final bill but some amendments were not able to be passed in Congress and the bill had to be watered down to get final approval. It does require regulation of speculators and of the derivatives market but the Commodity Future Trading Commission is not doing its job of enforcing these regulations yet. Speculators are driving up the price of commodities now like gasoline -- oil prices are rising not because of simple supply/demand this time and the Arab Spring -- pro democracy revolts and movements in the Middle East but because speculators are driving up prices. I urge federal regulators to protect the public from these speculators. No doubt Republican politicians and some Democrats receiving financial support of bankers, insurance companies, oil companies etc are siding with the big banks, big insurance, big pharma and big oil versus their own constituents and the public as a whole. We need consumers and taxpayers to be protected from predatory payday lenders, from credit card companies, credit reporting firms and banks engaging in fraudulent and unfair tactics -- including protecting us and retailers from unfairly high debit card swipe fees the banks impose. They can be lower and if they were prices could be lower and the retailers could still make money, consumers save more, and the banks still get some swipe fee revenue but less than currently. Banks are supposed to serve the public and provide loans and financial assistance for us to responsibly borrow and use the money for things we need -- a car loan, a student loan, a home loan etc -- financial system exists to serve the public not the bankers.

Your rules should require at least a five year deferral period for executive bonuses at big banks, ban executive hedging of their pay packages, and require specific details from banks on precisely how they ensure that executives will share in the long-run risks created by their decisions. It should apply to the full range of important financial institutions, and draw in all the key executives at those companies.

Once this rule is passed, only you will know the details of its enforcement. But it's important for the public to know the progress you are making on this vital issue. You should report back to the public annually with a detailed report on progress in creating accountability for Wall Street pay.

Referencing Docket No.'s:

OTS:   RIN 155-AC49
OCC:  RIN 1557-AD39
Fed:    RIN 7100-AD69
SEC:   RIN 3235-AL06
FHFA: RIN 2590-AA42
FDIC:  RIN 3064-AD56


Mr. Maneesh Pangasa