Comment Text:
i0-001
COMMENT
CL-02998
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[email protected]
Friday, January 22, 2010 7:59 PM
secretary
Public Submission for 2010-00456
Public Submission for 2010-00456.zip
Please refer to the attached file.Please Do Not Reply This Email.
Public Comments on Regulation of Off-Exchange Retail Foreign Exchange Transactions and
Intermediaries:
Title: Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries
FR Document Number: 2010-00456
Legacy Document ID:
RIN: null
Publish Date: Wed Jan 20 00:00:00 EST 2010
Submitter Info:
first name Joshua
last name Graham
address1
city
country
us state
zip
company
RIN 3038-AC61
Here is the short version
DO NOT SET ANY LIMITS on leverage for retail forex. I already have a negative position
towards the limiting of leverage for usa nfa member brokerages to 100:1.
Here is the longer version.
1) There is absolutely ZERO need for any more reduction in leverage. Please allow traders
to be traders. What benefit does this have to the NFA or CFTC or to the FOREX market?
2) Traders are already pissed at the fact that you disabled hedging and capped leverage to
100:1. Now it makes you look like an idiot.
3) You also discourage brokers from wanting to become CFTC/NFA members because why
would they want to deal with the additional bureaucracy? It would be much cheaper for them
to to simply setup shop in a regulated, non-usa location.
4) If you really want to do something positive for forex traders, make SEGREGATED
CUSTOMER FUNDS ACCTS mandatory. Now that would protect traders. If a broker
decides to take off and run, the client funds are there and insured. Just like in the futures
markets. Put a 5 business day deadline for withdrawals to be processed. And if not, customer
can go directly to bank to which funds are being held and request a withdrawal. They have 3
business days to honor it.
Now to be fair, the funds may not necessarily need to be in a segregated acct all the time, but
at least @ rollover profits and losses must be settled daily..Joshua Graham
Kemetic Research Group LLC
404 567 4746
