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Comment for Proposed Rule 75 FR 3281

  • From: Yves Wang
    Organization(s):
    Duke University

    Comment No: 3490
    Date: 1/24/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03490
    From:
    Sent:
    To:
    Subject:
    Yves Wang
    Sunday, January 24, 2010 10:10 AM
    secretary

    Regulation of Retail Forex
    *RIN 3038-AC61
    Dear CFTC officials,
    Before I lay out my opinion, I would like to tell a very short story.
    When I was at 10th grade in China, one day the school was organizing a
    spring outing event. All students were very excited about it. But on the
    day when we were about to set out, we were informed that the event was
    canceled. The reason? It turned out, at a meeting, the Mayor of Beijing
    asked the chief official of education in Beijing to guarantee the
    general safety of students at schools. Then, to "guarantee" the safety,
    for the next 2 years, no out event was ever had for Beijing's middle
    schools. You could imagine how disappointed and angry the students were.
    Well, my opinion is that: to control the risk does not mean to
    completely eliminate the risk. There exist various ways to achieve the
    goal of controlling risk and better protecting people like us,
    non-institutional traders (investors).
    First, I agree with the CFTC that changes need to be made to the current
    condition of retail forex. However, just like it is wrong to have a
    single high leverage 100:1 for everybody, it is also unreasonable to
    have a single low leverage of 10:1. Instead, I propose that the CFTC
    require every retail forex provider offer multiple levels of leverage,
    ranging from 10:1 to 200:1. (10:1 is even lower than the forex leverage
    in China)
    Second, to help people make the right choice of leverage ratio, to help
    people find a leverage ratio that suits best to their risk taking
    ability, I propose the CFTC require the forex retailers provide detailed
    information and education about risk management, explain clearly the
    need and method to choose an appropriate leverage ratio. This should
    not
    be very hard to attain as I have seen similar evaluation of risk taking
    ability in stock brokerages.
    Third, on the customer's side, the CFTC should mandate all individual
    forex traders go through several classes (or online webinars) about the
    risk levels and leverage ratios. Yes, just make underlying math clear to
    everyone. Even after understanding the risks, the choice of leverage
    ratio is still subjected to the control from the retailer. It is just
    like what TD-Ameritrade did to me for my stock options trading: the
    evaluation showed that my risk taking ability is not suitable to deal
    uncovered options, even if I chose to do uncovered options, they still
    would not allow me to.
    In conclusion, I propose that the CFTC make improvement of retail forex
    regulation, by requiring the retailer to provide flexible leverage ratio
    and better, comprehensive education, and by requiring the trader to
    learn the necessity of selecting a suitable risk level. I believe thisi0-001
    COMMENT
    CL-03490
    would make everyone happy.
    Thank you very much for reading my e-mail.
    Best regards,
    Yi(Yves) Wang
    Department of Biochemistry
    Structural Biology & Biophysics Program
    Duke University
    BS: University of Science and Technology of China
    School of Life Sciences, National Laboratory for Physical Sciences
    at Microscale
    Tel: +1-919-236-3307 (Cell)
    +1-919-684-0235 (Lab 1)
    +1-919-660-1634 (Lab 2)
    Office: A20 LSRC / 5301 FFSC
    E-Mail: [email protected]
    Mail: Box 90317, Chemistry Department