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Comment for Proposed Rule 75 FR 3281

  • From: Robert Watt
    Organization(s):

    Comment No: 1536
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-01536
    From:
    Sent:
    To:
    Subject:
    Robert Watt
    Thursday, January 21, 2010 4:20 AM
    secretary
    'Regulation of Retail Forex'
    The purpose of this email is to provide my comment and opinion regarding the proposed changes to
    retail foreign exchange dealers. While I am all for oversight of the RFEDs to help ensure integrity of
    these firms and to help protect the individual retail trader I have an enormous concern about the
    limitations that continue to be imposed on the customer.
    As a FOREX trader for over five years I have been treated fairly by my RFED. One of the primary
    reasons I was drawn to trading the FOREX was the leverage offered by the RFEDs. Leverage in trading
    foreign currency is critical for the average retail trader to be able to make money without having to have
    large sums of capital. By implementing the proposed regulation of limiting accounts to a 10-to-1
    leverage you would be impacting a very large number of individuals who are able to make an income
    from trading. I understand how leverage works and it not only creates the opportunity to earn more but
    also increases the risk of higher losses. By setting stop losses and using money management you are
    able to control the downside risk while still being able to have the upside from the leverage.
    I've dealt with several RFEDs in my five years of trading the FOREX and everyone of them
    distribute
    forex-specific risk disclosure statements to their customers. They provide detailed information in the risk disclosures
    and require you to confirm your understand these of the risk when opening an account. It is clearly communicated in
    the documentation when opening an account that trading the FOREX has a higher risk and is not suited for everyone.
    I understand the governments role in regulation to protect and serve the interest of both the
    people and the government. VVhat really concerns me is when my personal freedom of choice
    is being impacted. I should have the right to select what leverage/risk I'm willing to accept. My
    level of risk is a personal decision and should not be dictated by the CFTC, NFA or any other
    commission.
    An alternative solution would be for the REFDs to offer various levels of leverage and the
    individual select the ratio based on his/her own risk tolerance which they acknowledge on an
    application when they sign up for an account.
    If the proposed regulations are to help protect the consumer/retail trader then focus on the
    RFEDs to ensure the financial integrity of the firms but do not penalize the customer in the
    process.
    Sincerely,
    Robert Watt