Volcker-Comment-Letter-11.5.2010

CENTER FOR CAPITAL MARKETS COMPETITIVENESSOF THEUNITED STATES CHAMBER OF COMMERCE1615 H STREET. NWDAVID T. HTRscHMANNWASHINGTON. DC 20062-2000PRESIDENT AND CHIEF EXECUTIVE OFFICER202/463-5609• 202/955-1152 FAXdavid.hirschmann@uschamber.comNovember 20105,Financial Stability Oversight Council1500 Pennsylvania Avenue, NW.Washington D.C. 20220Re: Public Input for the Study Regarding the Implementation of theCertain Relationships with HedgeProhibitions on Proprietary Trading andand Private Equity. FR Doc 2010-25320FundsTo the Members of the Financial Stability Oversight Council:The U.S. Chamber of Commerce (“Chamber”) is the world’s largest businessfederation representing over three million companies of every size, sector, and region.The Chamber created the Center for Capital Markets Competitiveness(“CCMC”) to promote a modern and effective regulatory structure for capital marketsto fully function in a 21st century economy. The CCMC welcomes this opportunityinput for the implement an important provision of financialto provide study toregulatory reform that mandates prohibitions on proprietary trading, more commonlyknown as the Volcker Rule.The CCMC supports the intent of attempting to liniit unnecessary risk taking;however, the implementation issues presented by the Volcker Rule may create asystem that is too rigid for vibrant, dynamic capital markets. The CCMC has seriousconcerns that the Volcker Rule is unworkable and will harm the U.S. ...