February 9, 2012
I’m writing in support of a strong Volcker Rule.
It's not that I, my family, friends, community, pretty much the whole nation and its global trading partners were affected by the economic collapse of 2008, and we don’t want it to happen again. That should be enough on its own.
It's that backing some financial institutions, on the basis that they should focus on providing secure and personal financial services to the economy, over institutions that are out there for people that can afford to take more risk is both immoral and damaging to the industry itself.
First it's blatantly immoral. In backing one group of proprietary traders and thereby providing them with the leverage to outperform the traditional experts we're essentially saying, "thanks for all you've personally invested in learning your part of the industry and getting to know all its subtleties and nuances, but we're going to rig the rules to give a ludicrously unfair advantage to these guys over here; the ones that are supposed to be focused on providing more conservative, less risky, financial instruments but have somehow fallen into the wrong end of the industry and want to take part in riskier speculation instead." I can understand a bit of animosity to folks that take large risk with money (as a Christian the concept of getting something you haven't earned and don't need through gambling is objectionable), but it's their choice to do so and I'm perfectly fine as long as they do it in a manner that doesn't expose grotesque involuntary incorporations of others' assets. They have their set of beliefs and morals and can find a way to make a living at it without including me or endangering others, then fine. I wish they'd be more considerate of their duty to their fellow man but they're within reason given they can be compelled to some sense of respectability for the nation as a whole. I don't think we should give actors that want backing AND the ability to engage in riskier activities the implicitly unfair advantage they have over the traditional proprietary trading firms that respect their risks as their own.
There's also the culture of the respective portions of the industry that are being unbalanced, and to a sway that drives men to be increasingly crass and vulgar in their sense of responsibility to their fellow man. As the traditionally more conservative portions of the industry find themselves pulled deeper and deeper into riskier waters by the imbalance in power that has been heavily tipped in favor of the greediest of their rank, others in the traditional banking industry find themselves needing to abandon their traditional roles and the culture that goes with them in order to stay competitive and be able to have enough capitol base to supply lending for assets that have had their values over-inflated by the crass dealings and leverage provided by federally backed lenders that aren't in it for the people and communities they are lending to, but rather, just for the money.
Not only are the greediest actors in the industry being given unfair leverage to out compete the traditional experts, they're being given undue leverage to sway the entire culture of our financial industries.
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 through the promotion of the riskiest of players and their cultural values. They should not be treated lightly.
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 rejected.
Thank you for considering my comment,
Andrew Pilling
Huntsville, TX