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Comment for Proposed Rule 75 FR 3281

  • From: Patricia S Clark
    Organization(s):

    Comment No: 2975
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02975
    From:
    Sent:
    To:
    Subject:
    Digitalight
    Friday, January 22, 2010 7:23 PM
    secretary
    Regulation of Retail Forex
    Hello,
    As a Forex trader I am against any plans to limit retail forex leverage to 10:1. I will have to move my accounts
    back overseas to get the same full leverage and people who work in this industry in the United States will lose
    their jobs.
    This will also have an impact on the US dollar and will reduce US tax collection as many foreign governments
    don't
    report earnings. Last year I moved one $25K account from Gain Capital in London back to the US with FXDD
    because
    of a good lB. This year I opened a second account with FXDD and then your new limit of 100 to 1 leverage was
    forced on me.
    My earnings this year to date could have been 25% higher if the 200 to 1 was left alone. At 10 to 1 I will transfer
    three accounts
    worth over $45K back to overseas brokers to reclaim my 200 to 1 leverage and therefore reclaim better earnings.
    Thus 10-1 will basically cost thousands of US Jobs and hundreds of millions in tax revenues. There is a lack
    of intelligence running in the CFTC. Seriously! If the goal is to reduce the odds of new traders losing all their
    money
    then you should have a graduated leverage based on capital in an account. For example,
    under $2,000 give traders 25:1 or up to 50:1 and for accounts over $5k or $10k give the entire 200:1 leverage.
    It's only the traders with a few hundred dollars in accounts that you should hit by this arcane rule. Leave the
    professional traders alone with the leverage and risk they need. Any good trader risks no more than 1 or 2% of
    their
    account in trades and if you're a scalper doing multiple trades at once THIS RULE WILL HURT their money
    management
    algorithms and thus cause the very thing you hope to prevent, LOSSES.
    Another solution is to HARD CODE maximum losses of 100 pips. I personally limit my losses when wrong to
    50 pips max thus trading more lots and when I'm right my trades go 25 to 100 pips. Cutting leverage
    drastically will change how I trade, that is until I open foreign accounts again which EVERY experienced trader
    will do. This rule is damaging and I'd like a response as to the reasons behind it. But I have a feeling you do not
    care about a small trader such as me. If you do, then respond and tell me how your rules benefit me. When you
    cut
    my earnings potential, you also cut the US tax revenue amonut as well.
    Patricia Sue Clark
    1103 Seton Hall Lane
    Pflugerville Texas 78660
    512.670.2224
    [email protected]