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Comment on Financial Reform Implementation
May 23, 2011
To whom it may concern
Re: NPR(proposed Regulation)
I would like to voice my concerns over Collins amendment & Basel of Dodd-Frank Reform and the changes to Tier 1 Capital status of preferred Stocks.
Part of the responsibility in this reform situation has been to bolster confidence in the markets, Institutions and Investments. Recent speculation with regards to new regulation as pending is affecting my confidence in markets and investing in these trust preferred securities. When a fixed income investment is marketed and sold there is a YTM(yield to maturity) & YTC(yield to call) when applicable. Some of these trust preferred securities have a call in the future say 2015 as an example. The Individual then expects to receive there coupon 'til the call as a worst case scenario. We don't need some legal trickery hidden on a prospectus nor newly adopted proposed legislation creating ambiguity of the maturity or call features of these investments. There is enough risk in markets and underlying as we have hopefully learned from events of the past few years that we do not need another reason to lose public confidence.
While most of these issues would not matter to securities trading at par or under. Those trading at a premium would as investors could loose, and have lost significant money. I would propose that the instruments continue to count as capital until they are eligible to be called, and that the call date remain to be viewed as such without enacting these special hidden call features. I heard the my fingers were crossed clause back in elementary school. Hopefully we have matured as members of society. The at large issue then seems to be if the "fingers crossed" scenario occurs I would interpret that to mean a new call of 2013 or sometime frame of the 3 year phase out in order to be called in at par else bought in at market price if it behooves them. The present situation seems to be institutions rumored to call at will. So in essence chaos as the individual is poised to be taken advantage of once again. Hopefully this is not the case.
I would welcome your feedback, and look forward to further discussion and resolution.
D.P. Mac Investments, LLC
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