Comment Text:
i0-001
COMMENT
CL-02197
From:
Sent:
To:
Cc:
Subject:
Michael Flowers
Thursday, January 21, 2010 8:05 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.
Don't let proposal RIN 3038-AC61 become an expensive lesson in unintended
consecluences ....i0-001
COMMENT
CL-02197
Thank ~/ou.
Michael Flowers
Michael Flowers
Discontentment is caused by ....ignoring todays blessings while chasing tomorrows.
