Subject: File No. S7-27-10
From: Chris Norem
Affiliation: Consultant

November 15, 2010

Our country is taking steps to improve our financial situation and the laws surrounding it. One such law, the Wall Street Reform and Consumer Protection Act (H4173), is currently making its way through your commission.

This law was created to help bring stability to our markets and provide more transparency in the future. As you consider two different versions of regulations affecting this law, I hope you will bear this purpose in mind.

The two regulations are the 20/40 Rule and the 5% Rule. While HR4173 requires derivative transactions to go through a clearinghouse, these two regulations could have very different effects. The 20/40 Rule would restrict big banks ownership of these clearinghouses to a cumulative total of 40%. The 5% Rule, on the other hand, will not place a restriction on the total percentage of each clearinghouse that could be owned by big banks

By not limiting big banks influence of the ownership of these clearinghouses, you could very easily have a situation where banks are financially controlling the very institutions put in place to protect consumers. This makes no sense.

I urge you to throw out the 5% Rule and instead support the 20/40 Rule, putting consumers above the unrestrained potential of big banks. Thank you for your consideration.