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Comment for Proposed Rule 75 FR 3281

  • From: Ann Sinclair
    Organization(s):

    Comment No: 2738
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02738
    From:
    Sent:
    To:
    Subject:
    Ann Sinclair
    Friday, January 22, 2010 2:13 PM
    secretary
    10:1 Leverage
    To Whom It May Concern:
    Reducing leverage to 10:1 on US accounts is not a solution for "protecting"
    investors. Rather it serves to effectively reduce one of the few remaining liquidity
    opportunities for individuals who have smaller accounts from which to work, and
    further restrict retail traders from market participation. It will serve to drive more
    accounts offshore, and increase the already restrictive nature of trading under US
    rules.
    There is already a safety mechanism in place in the FX market; the lot size
    positioning, which can reduce risk effectively, and is controlled by the trader, not
    the regulator.
    If CFTC wishes to address risk management, it should aggressively enlist or
    regulate brokers in restricting lot size relative to account size through education
    and broker participation. For example, no trader with an account smaller than 10K
    should be trading standard lots as a rule; rather trading lesser sizes until their
    account can manage the risk required for full lot trading.
    FX is not the equities market. It is a different market, and as such must be
    managed differently. Low leverage is not the answer. Proper, educated risk
    management by the individual trader is.
    Ann Sinclair