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Comment for Proposed Rule 75 FR 3281

  • From: Adrian Oncel
    Organization(s):

    Comment No: 3607
    Date: 1/24/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03607
    From:
    Sent:
    To:
    Subject:
    adrian oncel
    Sunday, January 24, 2010 7:26 PM
    secretary
    Regulation of Retail Forex
    Attn : David Stawick, Secretary, CFTC and ALL CFTC policymakers
    As a non-affiliated US-based Retail FX trader, please note for the record that I am STRONGLY
    OPPOSED to the 10-1 leverage limit as proposed in RIN 3038-AC61 relating to the Regulation of
    Retail Forex. Counter-productive effects This limit would in NO way protect, aid or benefit me but
    rather would greatly harm me since this restriction, if passed, would require that I submit
    substantially more margin-funds into non-protected, non-FDIC insured, non-SIPC eligible accounts,
    actually exposing me to increased risk in the event of bankruptcy of my Forex Broker.
    I would NOT divert my business into regulated-Futures trading ,but rather would cause me to seek
    a higher-risk offshore FX broker to trade through. You will eliminate one of the greatest benefits of
    trading Forex : my ability to efficiently deploy my own trading capital in the way that I choose.
    Lower FX vols require far greater leverage FX volatilities are generally substantially lower than in
    the Equities or Futures market. Therefore, significantly more leverage is required simply to capture
    equivalent trading opportunities. I do not want the CFTC to treat me like a child and dictate how I
    should trade. While 100-1 leverage is available to me - should I choose it - I am never forced to
    use it. The bottom line is that OTC Retail Forex trading is NOT Futures trading. Please do not try to
    treat it as such! PLEASE STRIKE YOUR PROPOSED 10-1 LEVERAGE LIMITATIONS. Don't let
    proposal RIN 3038-AC61 become an expensive lesson in unintended consequences.
    Thank you,
    Adrian Oncel