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Comment for Proposed Rule 75 FR 3281

  • From: Nathan Wyss
    Organization(s):

    Comment No: 3004
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03004
    From:
    Sent:
    To:
    Subject:
    [email protected]
    Friday, January 22, 2010 8:16 PM
    secretary
    Public Comment Form
    Below is the result of your feedback form. It was submitted by
    ([email protected]) on Friday, January 22, 2010 at 20:15:57
    commenter_subject: Reduced Leverage in Retail FOREX RIN 3038-AC61
    commenter frdate: 1/13/10
    commenter frpage: RIN 3038-AC61
    commenter comments: Attention David Stawick,
    I am writing you to express my extreme disapproval
    of the proposed rule changes you want to make to
    retail FOREX trading. I cannot imagine the real
    reason you want to do this. I assume you are
    telling people the reason is you want to make it
    safer for the average person to trade FOREX by
    lowering the available leverage, thus, in theory,
    lowering the maximum amount of money one can lose
    while trading. While it may be true that there are
    citizens of the U.S. who do not understand the
    concept of leverage well enough to be trading, yet
    these people trade anyway and many of them lose
    money. Where do I start on why this plan is so
    wrong?
    1. People who trade without fully understanding
    leverage will lose money because they most likely
    do not understand how to be a successful trader.
    Leverage is just one small piece of the pie. Even
    if you lower leverage to 10:1, and they some how
    still have enough money to fund their accounts to
    trade at that leverage, they will still lose their
    money for a million other reasons.
    2. Taking away my freedoms and all other traders'
    freedoms to protect people who should not be
    trading in the first place is anti-capitalist and
    anti-american. It's the equivalent of prohibiting
    stores from selling sharp knives because once in a
    while some one cuts themselves by behaving
    irresponsibly.i0-001
    COMMENT
    CL-03004
    3. Traders will be more likely to experience more
    margin calls at 10:1 leverage than 100:1 leverage
    for the simple fact that most retail traders do not
    have $100,000 to fund an account with to trade the
    same way they were trading at 100:1 leverage with a
    $10,000 account. This new rule would punish many
    currently responsible and profitable traders
    because of this issue.
    4. You would take away the main income and side
    income of tens of thousands if not hundreds of
    thousands Americans by stripping them of their
    ability to trade they way they are trading right
    now. Not only would traders lose their income, but
    brokers would go out of business, or at best
    downsize, do to the sudden lack of business and
    thousands of people would be put directly out of
    work.
    5. Some traders may move their accounts off shore
    to continue to trade. But the mass reduction in
    trading will impact the markets' behavior and could
    render many trading systems ineffective. Traders
    would only figure this out after many consecutive
    losses. That translates into lost money, as well
    as the lost time and effort developing those now
    useless trading systems.
    In the first paragraph I said I cannot image the
    real reason you want to make these rule changes,
    specifically the leverage reduction. I say this
    because these 5 points I mentioned above are quite
    obvious. I doubt you rode the short bus to school
    while wearing a helmet. I'll bet you are of above
    average intelligence. I'd also bet you realize the
    impact of reducing the maximum leverage in retail
    trading would be catastrophic to the industry, at
    least in the US. Much like the "First In First
    Out" rule, the reduced leverage does nothing to
    help us retail traders. Unlike the "First In First
    Out" rule, which is reduced to an annoyance by
    clever work-arounds, reduced leverage will most
    likely destroy my ability, along with countless
    other traders' ability, to continue trading.
    What is the real reason you want to reduce
    leverage? Do you have even one letter or email to
    support this rule change? Who exactly supports
    this rule change and why?i0-001
    COMMENT
    CL-03004
    Sincerely,
    Nathan Wyss
    commenter_name: Nathan Wyss
    commenter ~vithhold address on: ON
    commenter_addressl : 5111 Telegraph Ave #327
    commenter_city: Oakland
    commenter state: CA
    commenter_zip: 94609
    commenter fax: 510 827-5889
    commenter~hone: 510 827-5889