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The Business Roundtable writes to share the combined perspectives of CEOs at these member companies regarding the risk retention requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”).

As House Subcommittees hold a hearing examining the impact of the proposed rules to implement Basel III Capital Standards, our organizations would like to draw your attention to the unintended consequences of Basel III upon non-financial businesses.

The Coalition for Derivatives End-Users is pleased to respond to the request for comments by the Prudential Regulators during the extended comment period for the proposed rule entitled Margin and Capital Requirements for Covered Swap Entities.

In this regard, we have serious concerns about ISS’ proposed changes to its voting policy on board responsiveness to majority-supported shareholder proposals.

The Coalition for Derivatives End-Users is pleased to respond to the request for comments by the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation.

End users do not use derivatives to take on risk for speculative or investment purposes. Instead, end-user companies use derivatives to hedge or reduce risk.

Imposing unnecessary regulation on derivatives end-users, who did not contribute to the financial crisis, would create more economic instability, restrict job growth, decrease productive investment, and hamper U.S. competitiveness in the global economy.

The Coalition for Derivatives End-Users is pleased to respond to therequest for comments by the CFTC during the extended comment period for the proposed rule entitled  Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants.

We also continue to believe that mandating audit firm rotation is a drastic measure that would be excessively burdensome and would not provide any meaningful benefits for auditor independence, objectivity, or professional skepticism.

The passage of H.R. 2682 and H.R. 2779 in the Senate would help ensure that new regulations achieve these goals without impeding innovation, diminishing U.S. competitiveness, or restraining job creation and economic expansion.

BRT members have identified the costs and uncertainty associated with increasing federal regulation as a key barrier standing in the way of greater jobs creation.

H.R. 2682, the Business Risk Mitigation and Price Stabilization Act of 2011, and H.R. 2779, a Bill to Exempt Inter-Affiliate Swaps from the Regulatory Requirements of Title VII of the Dodd-Frank Act

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