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Comment for Proposed Rule 75 FR 3281

  • From: Steven Golledge
    Organization(s):

    Comment No: 3228
    Date: 1/23/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03228
    From:
    Sent:
    To:
    Subject:
    Golledge,
    Steven
    Saturday, January 23, 2010 11:20 AM
    secretary
    Regulation of retail forex
    Dear Sir/Madam:
    I have read with interest the proposed regulations on retail forex trading
    ID # RIN 3038-AC61.
    As a professional trader for more than 40 years, I am fully aware of the
    risks involved with margin trading and the possibility of sizeable losses if
    those risks are not properly managed. However, it is my experience that the
    reputable companies operating in this market provide ample tools to manage
    risk by the use of stop loss and other limit orders, and will automatically
    close positions to ensure that losses cannot exceed the available margin.
    I strongly believe that each customer should be allowed to determine the
    appropriate level of leverage for their own trading account, within the
    overall trading structure. While I agree that there should an upper limit on
    leverage, the existing 1% level is comparable to the margin required at the
    major exchanges and seems appropriate to this type of trading. A limit at
    the level proposed will likely encourage clients to move their accounts to
    other less-regulated geographies, thus increasing the risk for
    less-experienced traders
    In order to avoid disputes between the account holder and market maker, I
    would suggest that all account holders be required to submit their own
    leverage preference, in writing, with the information to be retained in the
    market-makers records for audit purposes.
    I request your reconsideration of this proposal.
    Respectfully yours,
    Steven Golledge