Ensuring Useful Access for End Users of Derivatives

The National Association of Manufacturers today sent a Key Vote letter to the U.S. Senate expressing the NAM’s support for the Chambliss/Shelby Substitute Amendment (SA 3816) to S. 3217, the super-expansive Restoring American Financial Stability Act, the financial regulation bill. Excerpt:

NAM members believe strongly that any derivatives reform effort should ensure business end-users’ continued access to OTC derivatives, providing them with greater financial certainty and allowing them to allocate resources to core business activities. In addition, we have called for clear exemptions from central clearing, bilateral margining and exchange-trading requirements for business end-users to avoid drawing large amounts of capital from business operations, including job creation.

We have serious concerns, however, that the current end-user exemption in S. 3217 (and in the pending Dodd Substitute) is not strong or clear enough. In addition, other provisions in the derivatives title could effectively eliminate the exemption for many companies and, in some cases, subject them to capital and margin requirements or higher costs.

Key votes, developed by a committee of NAM member companies, are used to determine a member of Congress’ rating on manufacturing-related measures.

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