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Comment for Proposed Rule 75 FR 3281

  • From: Nadaraja C
    Organization(s):

    Comment No: 2413
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02413
    From:
    Sent:
    To:
    Subject:
    Raj a.N
    Friday, January 22, 2010 1:48 AM
    secretary
    Regulation of Retail Forex
    Greetings Dear Secretary,
    Ref: identification number
    RIN 3038-AC61
    I am a full time retail forex trader.
    We understand CFTC is proposing to reduce leverage for the retail
    forex to 10"1.
    Currently, the Forex playing field favours large players like
    banks/Multinational companies/Hedge Funds.
    Banks have many advantages (as I understand)'-
    1.They have access to large capital for proprietary trading, and hence
    able to withstand large market swings against their position.
    2.They have privy info on ->when and how much currency their large
    corporate multinational clients wish to bring in or transfer out of the
    country. The banks can time the clients transaction and/or front run
    their own trades to benefit them.
    3.They work closely with Central Banks/Fed and may have access to
    insider info on interest rate changes etc.
    4.They have dedicated resources such as ->analysts
    (fundamental/technical) ,risk managers, traders(buy side/sell
    side), powerfull computers & software for number crunching and
    automated trading.i0-001
    COMMENT
    CL-02413
    5.Their trading cost (spread) is minimum since forex transactions are
    cleared at the Interbank network level.
    6.The bank also earns the spread (their main income in forex
    business)
    The retail forex trader only has a few advantages:-
    1.High leverage allows him to participate in the market with small
    capital.
    2.His "total operating cost" is small (spread + internet + electricity
    for computer etc)
    3.He can be nimble and small pip gains can offset the operating costs
    and produce net profit for the month end.
    If the leverage is reduced for the retail player :-
    1.Many retailers may not have adequate initial capital to participate
    and as a result have to exit the market.
    2.There will be decrease in " returns on capital invested".
    3.It will decrease the risk involved (for the remaining retail players)
    4.It will drive away retail traders to non CFTC regulated brokers
    The retail forex industry will shrink to a levell where many retail forex
    brokers and traders have to close/exit.
    CFTC should consider limiting the leverage for retail forex to 50:1
    rather than a drastic reduction to 10:1
    I would request and like to know what is the current and proposedi0-001
    COIMMENT
    CL-02413
    leverage for Banks and Hedge Funds.
    Thank You & Have a Great day.
    Best Regards
    Nadaraja.C (Raja)