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Comment for Proposed Rule 75 FR 3281

  • From: Daniel L Brown
    Organization(s):

    Comment No: 3367
    Date: 1/23/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03367
    From:
    Sent:
    To:
    Subject:
    Daniel L Brown
    Saturday, January 23, 2010 6:37 PM
    secretary
    Regulation on Retail Forex
    RIN3038-AC61
    I disagree with that proposed regulation to set the maximum leverage for U.S. retail forex to 10:1.
    The setting of the leverage so low would mean the demise of the U.S. based retail forex brokerage
    industry and less need for many CFTC employees impacted by the demise of the U.S. based retail forex
    brokerage industry. Why? Ask yourself, what would be the big picture impact of all U.S. retail forex
    traders moving all of their funds from the U.S. based to foreign based retail forex brokerage firms
    because of the proposed low 10:1 leverage? Also, how does lowering the leverage to 10:1 "foster open,
    competitive, and financially sound futures and option markets [includes forex since the expansion of
    CFTC oversight] as stated in CFTC's mission?
    The unintentional results of the maximum leverage of 10:1 is also inconsistent with the statement
    in CFTC's website which states "the CFTC assures the economic utility of the futures [forex] markets by
    encouraging their competitiveness and efficiency, protecting market participants against fraud,
    manipulation, and abusive trading practices, and by ensuring the financial integrity of the clearing
    process." How can the U.S. based retail forex brokerage industry be "competitive" when the CFTC
    proposes to limit the leverage to 10:1 while the foreign-based retail forex has a leverage as high as
    400:1?
    What is the Commodity Futures Trading Commissions (CFTC) true intent in proposing to set the
    maximum leverage for U.S. retail forex to 10:1 that is inconsistent with your own mission? I do not
    want this "so called" protection you are proposing in the form of maximum leverage of 10:1.
    Daniel Brown
    2051 Chevella Drive
    Dallas, Texas 75232
    (817) 456-3676