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Comment for Proposed Rule 75 FR 3281

  • From: Efim Kligman
    Organization(s):

    Comment No: 2290
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02290
    From:
    Sent:
    To:
    Subject:
    skligman
    Thursday, January 21, 2010 9:32 PM
    secretary
    Regulation of Retail Forex
    Dear Sirs,
    As a retail Forex trader for the last 4 years I'm very concerned about the proposed possible
    change. I understand that your intend is to protect naive and non-educated investors from
    losing their money in the forex market. But what will happen instead is that they will put their
    money in offshore brokerages with unregulated and unscrupulous people. This is what's
    happening with online casinos. Why then educated and conservative traders like me have to
    suffer?
    A leverage structure change in retail forex margining from 100:1 to 10:1 will force a great
    majority of forex business to be done offshore and thousands of U.S. (perhaps Canadian as
    well), jobs would be lost in the derivatives industry to European and other foreign competitors.
    Worse, U.S. forex customers would not be protected by the CFTC through these foreign
    accounts.
    It was clearly not the intent of the Congress to destroy the U.S. retail forex industry when the
    CFTC was given the authority to create rules for retail foreign exchange. Congress made it
    clear that the industry was to be policed, not abolished. The 100:1 leverage structure was
    changed from 400:1 earlier this year when the NFA submitted rules which the CFTC approved.
    This governance created clear guidance and market protection while keeping the United
    States competitive with the offshore competitors even though it was a higher requirement.
    With Gratitude,
    Efim & Svetlana Kligman
    Members of Toronto GTA 4X & Ontario Pipsters User Groups
    fkl igm an @rogers. com
    905-553-5436