Comment Text:
i0-001
COIMMENT
CL-02296
From:
Sent:
To:
Subject:
Stawick, David
Thursday, January 21, 2010 9:38 PM
secretary
FW: STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF
RETAIL FOREX PROPOSAL RIN 3038-AC61
From:
Kelly Reardon [[email protected]]
Sent: Thursday, January 21, 2010 7:09 PM
To: secretary
Cc:
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.
This limit will only have 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.
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.
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!i0-001
COIMMENT
CL-02296
PLEASE IMMEDIATELY STRIKE YOUR PROPOSED 10-1 LEVERAGE LIMITATIONS.
Don't let proposal RIN 3038-AC61 become an expensive lesson in unintended consequences ....
Thank you.
Sincerely,
Kelly Reardon
