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Comment for Proposed Rule 75 FR 3281

  • From: Sandy Garrett
    Organization(s):

    Comment No: 2295
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02295
    From:
    Sent:
    To:
    Subject:
    Stawick, David
    Thursday, January 21, 2010 9:38 PM
    secreta ry < secreta ry@ C FTC. g ov >
    FW: STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN
    REGULATION OF RETAIL FOREX PROPOSAL RIN 3038-AC61
    From:
    Sandy Garrett [[email protected]]
    Sent:
    Thursday, January 21, 2010 9:09 PM
    To:
    secretary
    ¢c:
    Stawick, David; Smith, Thomas J.; Bauer, Jennifer; Penner, William; Cummings, Christopher W.; Sanchez,
    Peter
    Subject:
    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.io-ooi
    COMMENT
    CL-02295
    Don't let proposal RIN 3038-AC61 become an expensive lesson in unintended consequences ....
    Thank you.
    Sandy Garrett
    ~
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