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Comment for Proposed Rule 75 FR 3281

  • From: Neil M Patel
    Organization(s):

    Comment No: 3199
    Date: 1/23/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03199
    From:
    Sent:
    To:
    Subject:
    Neil Patel
    Saturday, January 23, 2010 10:06 AM
    secretary
    RIN 3038-AC61
    I definitely agree with the CFTC that we need to regulate the leverage in the FX markets. This over the
    counter market gives retail players 100:1 leverage and over 90%
    of these accounts get wiped out in the first month of trading. As a former sales trader for Forex Capital
    Markets, I explicitly remember that statistic very well.
    In fact, many of FXCM's leverage policies were aimed at taking advantage of that specific statistic...At
    one point, we offered 200:1 and 300:1 on mini accounts.
    While I understand that leverage is a double edged sword, I believe that limiting the impact of the bad
    side of the sword is the government regulators responsibility, for the
    greater good of the financial community. At present, the OTC FX market includes much more than
    simply Spot FX, it includes swaps, options, forwards and many
    other products, many of which trade on leverage as well.
    Before another systemic failure occurs in our financial markets, I believe it is important that those shops
    like Forex Capital Markets and FX solutions be required to reduce
    leverage quite alot to perhaps 3:1 or 2:1 to ensure the safety of their clients accounts as well the financial
    sector.
    Last year, we had the failure of one or two banks threaten the entire finance sector. NExt time, we might
    have one or two asset classes, like FX, threaten the entire sector.
    Please regulate this industry and please do it sooner than later.
    Kindest Regards,
    Neil Patel
    <225-772-7523>