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Comment for Proposed Rule 75 FR 3281

  • From: James Bilinski
    Organization(s):
    Bull Flag Asset Mgt LLC

    Comment No: 3893
    Date: 1/25/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03893
    From:
    Sent:
    To:
    Subject:
    James Bilinski
    Monday, January 25, 2010 7:29 PM
    secretary
    Regulation of Retail Forex
    Hello.
    RIN 3038-AC61
    I am opposed to the proposal to lower the max leverage in the FOREX
    I am part owner of an asset management firm trading in forex market. Changing the leverage
    anymore would inhibit us from operating at peak potential thus limiting returns for our cliental.
    The amount of margin required to take a position is NOT what dictates a responsible traders
    position size. We implement a strict risk management policy based on a small percentage of the
    account size (3%). Making us put up more margin per contract only disallows us to implement our
    strategy to the fullest. At the end of the day the risk and reward of a
    trade is immediately established once we take a position.
    When used responsibly, leverage is a not only a great
    asset
    to us professional traders but a
    necessity
    for small businesses like ours to grow faster.
    Where do you draw the line? Can we just be left alone for a decade so we can grow our business?
    Focus on catching the Bernie Madoff's of the world and leave us law abiding entrepreneurs alone!
    Thank You!
    James Bilinski
    Bull Flag Asset Mgt. LLC