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Comment for Proposed Rule 75 FR 3281

  • From: James M Needham
    Organization(s):

    Comment No: 4011
    Date: 1/26/2010

    Comment Text:

    i0-001
    COMMENT
    CL-04011
    From:
    Sent:
    To:
    Subject:
    [email protected] on behalf of
    James Michael Needham
    Tuesday, January 26, 2010 8:52 AM
    secretary
    Regulation of Retail Forex
    Dear Sir/Madam,
    You have asked for public comment on the above. I am a retail Forex Trader. My Identification
    Number is RIN 3038-AC61.
    I have several years experience in this field and intend to continue in it for many more. Although I am
    not an American citizen and do not reside in USA I value my American trading accounts. I do have
    trading accounts and trading platforms in other countries but over the years I have come to trade spot
    forex exclusively, online, through my USA account and brokerage.
    I find the USA retail forex environment well serviced, very professional and reliable; and I enjoy being
    part of it. I have searched for, but cannot find, any good enough reason (in my opinion) for you to want
    to subject the leverage in retail forex customer accounts to a 10-to-1 limitation. Why? It works well and
    responsibly as it is. I recall the adage "If it ain't broke, don't try to fix it!"
    I personally know and communicate with other forex traders, like myself, all over the world (but most of
    my contacts are in Europe, Africa and USA) and all are equally non-plussed by this proposed regulatory
    intrusion in our lives. I should be reluctant to shift my online forex trading base from USA and
    sincerely hope I will not have to face such a decision.
    May I ask a rhetorical question? Do you think that other countries would follow your example and
    impose similar limitations on leverage? (The online brokerage I used to use in London years ago is
    indicating that they would not.)
    These are my considered comments at this stage. Please review your basic assumptions and seriously
    question why such limitation was proposed and what it was supposed to achieve, and, importantly,
    consider also what it is likely to achieve.
    Yours sincerely,
    James M. Needham