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Comment for Proposed Rule 75 FR 3281

  • From: Charlie Delano
    Organization(s):

    Comment No: 1040
    Date: 1/20/2010

    Comment Text:

    i0-001
    COMMENT
    CL-01040
    From:
    Sent:
    To:
    Subject:
    charlie delano
    Wednesday, January 20, 2010 4:43 PM
    secretary
    Regulation of Retail Forex
    Dear Secretary Stawick,
    I am commenting on the CFTC [] s proposed rules to regulate retail forex trading. Currently, I work at
    FXCM and I wanted to state that I [] m glad to see the CFTC addressing the issue of forex fraud by
    requiring all solicitors be registered. I believe the licensing of solicitors will solve the problem of forex
    fraud and commend you for taking this action.
    However, I want to register my strong opposition to the rule that would limit leverage to 10:1. This rule
    will put the industry out of business in the United States. It was not the intent of Congress to do this and
    I strongly urge you to reconsider.
    I have worked at FXCM for almost ten years. I have seen this industry grow and blossom and am
    agonized that it would be shut down in the midst of a brutal recession with 10% unemployment. Even
    as I write this my company is hiring twenty people due to the success of our firm and the overall growth
    of this industry. Our firm employs over 500 people in the United States in places like Texas, California
    and New York. It is quite a success story.
    Yet, this 10:1 leverage rule will put an end to the domestic forex industry that we are a part of. As you
    can see from the many comments about this rule, forex traders will not accept 10:1 leverage. We won[]t
    be able to compete with UK brokers where leverage is 200:1. The end result will be a mass migration of
    the business to the United Kingdom or to other unregulated jurisdictions. Fraud will get worse, traders
    will be less protected and the whole point of getting solicitors to register and get licensed will become
    moot.
    Finally, as a fellow American, I am pleading with the Commission to consider the thousands of jobs at
    stake here. These are good paying, high tech jobs in a healthy and growing industry. The people who
    work in the retail ~ industry are not nameless, faceless statistics to be discounted as collateral damage.
    They are real people with mortgages, spouses, children and loved ones who rely on the retail forex
    industry for their livelihood. I myself have family members who will be directly affected by the
    elimination of this industry. My job allows me to care for my sick mother by placing her in a private
    assisted living home. Should I lose my job and be forced to go on unemployment I[]11 no longer be able
    to care for her. What am I supposed to do then? That is just my story. But each person who works in
    retail FX has their own story. I would hope the Commission would take this into consideration wheni0-001
    COMMENT
    CL-01040
    debating this rule.
    The CFTC should nurture, guide, and yes, regulate this industry. But the 10:1 leverage rule goes far
    beyond that.
    Please, don []t destroy the U.S. retail forex industry.
    Charlie Delano
    2217 Ivan St
    #223
    Dallas, TX 75201