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Comment for Proposed Rule 75 FR 3281

  • From: William Boyers
    Organization(s):

    Comment No: 2017
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02017
    From:
    Sent:
    To:
    Subject:
    william boyers
    Thursday, January 21, 2010 5:23 PM
    secretary
    Regulation of Retail Forex
    Dear Secretary Stawick,
    I am a retail FX trader holding an account with a US broker. While I applaud many of the things that
    the CFTC does to regulate and protect me as a trader, I am very opposed to and strongly believe
    limiting maximum leverage in retail FX to 10-1 (RIN 3038-AC61) is not a good idea. I believe that
    such limitations will actually have an opposite influence than intended.
    I'm sure you agree proper money management is key to successful investing no matter the vehicle. I am
    sure that reducing the margin for FX trading in this case could in fact reduce the protection that it
    intends. Some of the issues I see are,
    Traders with the additional funds necessary to trade at 10-1 will thereby be depositing ever more
    funds into FDIC/SIPC unprotected holdings. In the even the broker institution fails, more funds
    are at risk, not less.
    It is likely that many traders will clear their NFA/CFTC regulated brokers and seek non-
    regulated brokers offering higher margins but potentially unscrupulous dealing practices.
    For those that choose to invest a portion of their portfolio into retail FX, I do believe there should be
    some implemented regulations that currently don't exist. I think that NFA/CFTC regulated brokers
    should
    Be required to offer a choice of margin leverage including 1 : 10 but not higher than 1 : 100 to suit
    the traders tolerance for risk and trading style.
    Require a certain minimum opening deposit based on margin level to deter persons with little to
    no real "risk" capital.
    Again, I am in strong opposition to this particular proposed regulation and am disappointed at the
    thought of the myriad of consequences that will result if it is enacted. Thank you very much for your
    service and your time.
    Best Regards,
    ---William Boyers