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Comment for Proposed Rule 75 FR 3281

  • From: Joshua Glazebrook
    Organization(s):

    Comment No: 1434
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-01434
    From:
    Sent:
    To:
    Subject:
    Joshua Glazebrook
    Thursday, January 21, 2010 12:52 AM
    secretary
    Re: Regulation of Retail Forex
    I forgot to mention the bit added in red.
    RIN3038-AC61
    To VVho It May Concern,
    Information has been going around that the CFTC are going to introduce a leverage limitation
    of "10:1", on every currency pair including the most highly traded pair like the EURUSD,
    USDJPY, GBPUSD, AUDUSD, USDCHF, USDCAD, EURJPY or GBPJPY.
    To put it bluntly the people who proposed this idea within the CFTC are flipping nuts. All you
    are going to do is close down legitimate USA based forex businesses and limit the abilitieis of
    both trader and retail forex broker alike. I believe an internal investigation to see whether any
    CFTC proposer of this 10:1 leverage limitation has any vested interest in off shore forex broker
    businesses, because it is obvious to me that these are the people who stand to benefit by such
    an excessive, extreme ruling.
    If you want to stop illegitimate forex dealers from doing illegitimate stuff, have a tick analysis
    rule to prevent fake slippage / gappage in the bid / ask quotes. Or you could have no requote
    rule allowed in the retail forex market as they are not trading in the complete market but a sand
    box market where slippage/gappage is a made up scenario.
    Maybe if your aiming to protect the new trader, the new trader must take a test that
    demonstrates that they understand the effects of leverage. Don't screw up an entire industry
    because there are a few stupid people that don't understand the risk they are entering into.
    There are many brokers around the world now offering more than 100:1 and traders will very
    quickly pull all there money out of the USA brokers and migrate to international brokers if a
    10:1 leverage limitation or even a 50:1 leverage limitation is introduced.
    As a customer of a retail market broker I enjoy high leverage (200:1 (as I have now moved to
    Australian brokers and was with a USA broker (IBFX) due to the last lot of stupid laws that
    were introduced)), as I have a high tolerance to risk and understand the negatives. However,
    the high leverage and the significant trends found in the forex market makes it possible for
    every person to make a living out of trading and not just the big financial institutions.
    A 10:1 leverage limitation on major pairs or even the larger crosses, is just plain stupid. A 50:1
    leverage limitation isn't good enough for most traders.
    Major USD pairs in my opinion include EURUSD, USDJPY, GBPUSD, AUDUSD, USDCHF
    and USDCAD.
    Significant crosses include: EURJPY, GBPJPY, AUDJPY, CHFJPY, EURGBP, EURCHF,
    GBPCHF, EURAUD and GBPAUD.i0-001
    COMMENT
    CL-01434
    Yours sincerely
    Joshua Glazebrook
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