Comment Text:
i0-001
COMMENT
CL-04023
From:
Sent:
To:
Cc:
Subject:
Andy Bisulca
Tuesday, January 26, 2010 9:39 AM
secretary
Stawick, David ; Smith, Thomas J.
; Bauer, Jennifer ; Penner, William
; Cummings, Christopher W.
; Sanchez, Peter
I STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF
RETAIL FOREX PROPOSAL RIN 3038-AC61
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 senseless 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-SlPC eligible accounts, actually exposing me to increased risk in the event
of bankruptcy of my Forex Broker.
¯
would NOT divert my business into regulated-Futures trading (as the CFTC is probably
hoping), but rather would cause me to seek an unreliable, higher-risk offshore FX broker
to trade through, whose practices might be questionable.
¯
would 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 Volumes 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.
Nanny Not Needed
I do not want the CFTC to treat me like a child and dictate how I should trade. VVhile 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 IMMEDIATELY STRIKE YOUR PROPOSED 10-1 LEVERAGE LIMITATIONS.
Don't let proposal RIN 3038-AC61 become an expensive lessonin unintended
consequences ....
Thank you.
Andy Bisulca
