Comment Text:
i0-001
COMMENT
CL-01333
From:
Sent:
To:
Cc:
Subject:
David Gilbert
Wednesday, January 20, 2010 10:58 PM
secretary
Stawick, David ; Smith, Thomas J.
; Bauer, Jennifer ; Penner, William
; Cummings, Christopher W.
; Sanchez, Peter
STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF
RETAIL FOREX PROPOSAL RIN 3038-AC61
Attn
¯
David Stawick, Secretary,
CFTC
and ALL CFTC policymakers:
As a non-affiliated US-based Retail FX trader, please note for the
record that I am STRONGLY OPPOSED to the 10-1 leverage limit as proposed
in RIN 3038-AC61 relating to the Regulation of Retail Forex.
Counter-productive effects
This senseless limit would in NO way protect, aid or benefit me but
rather would greatly harm me since this restriction, if passed,
¯ would require that I submit substantially more margin-funds into
non-protected, non-FDIC insured, non-SIPC eligible accounts, actually
exposing me to increased risk in the event of bankruptcy of my Forex Broker.
¯ would NOT divert my business into regulated-Futures trading (as the
CFTC is probably hoping), but rather would cause me to seek an
unreliable, higher-risk offshore FX broker to trade through, whose
practices might be questionable.
¯ would eliminate one of the greatest benefits of trading Forex : My
ability to efficiently deploy my own trading capital in the way that I
choose.
Lower FX vols require far greater leverage
FX volatilities are generally substantially lower than in the Equities
or Futures market. Therefore, significantly more leverage is required
simply to capture equivalent trading opportunities.
Nanny not needed
I do not want the CFTC to treat me like a child and dictate how I should
trade. While 100-1 leverage is available to me - should I choose it - I
am never forced to use it.
The bottom line is that OTC Retail Forex trading is NOT Futures trading.
Please do not try to treat it as such!
PLEASE IMMEDIATELY STRIKE YOUR PROPOSED 10-1 LEVERAGE LIMITATIONS.i0-001
COMMENT
CL-01333
Don't let proposal RIN 3038-AC61 become an expensive lesson in
unintended consequences ....
Thank you.
Sincerely,
David Gilbert
President
Sirius Soft~vare Quality Associates
[email protected]
727-692-6792
~wwv.linkedin.com/in/davidleegilbert
