Comment Text:
i0-001
COMMENT
CL-04071
From:
Sent:
To:
Subject:
Stawick, David
Tuesday, January 26, 2010 12:42 PM
secretary
FW: STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF
RETAIL FOREX PROPOSAL
RIN 3038-AC61
From: Smith, Thomas J.
Sent: Tuesday, January 26, 2010 12:39 PM
To: Stawick, David
Cc: Cummings, Christopher W.; Bauer, Jennifer; Penner, William; Sanchez, Peter
Subject: FW: STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF RETAIL FOREX PROPOSAL RIN
3038-AC61
David,
I am forwarding this email to you as I don't see that [Vlr. Richardson included you or the Secretariat on his original
email. I also forwarded a different email commenting on the proposed rule to the Secretariat yesterday.
From: Hasalah Richardson [mailto:[email protected]]
Sent: Tuesday, January 26, 2010 12:21 PM
To: Smith, Thomas J.; Bauer, Jennifer; Cummings, Christopher W.; Sanchez, Peter; Penner, William
Subject: STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF RETAIL FOREX PROPOSAL RIN 3038-
AC61
ttn: David Stawick, Secretary, CFTC and ALL CFTC policymakers:
As a non-affiliated US-based Retail FX trader, please note for the record that I amSTRONI~/Y 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-SIPC
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 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.
Nanny not needed
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
IMMEDIATELY STRIKE YOUR PROPOSED 10-1 LEVERAGE LIMITATIONS.
Don't let proposal RIN 3038-AC61 become an expensive lesson in unintended consequences ....
Thank you.
