Date: November 7, 2013

Issue: Volcker

To:  Federal Reserve, FDIC, SEC, OCC, CFTC

Filing Type: Regulatory 

Description: CCMC summited a detailed letter to the agencies that are working on the Volcker Rule, requesting that instead of finalizing the Rule by year end, regulators should repropose the rule.  As previous comment letters articulated, we believe that the proposal will impede the ability and increase the cost of non-financial businesses to raise capital and manage risk and we don’t see how these concerns could be addressed by any final rule.  In addition, we believe that before the Volcker Rule is finalized companies should have the opportunity to comment on what must certainly be substantially altered from the original proposal.

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