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Comment for Proposed Rule 75 FR 3281

  • From: Kevin S Raper
    Organization(s):

    Comment No: 4103
    Date: 1/26/2010

    Comment Text:

    i0-001
    COMMENT
    CL-04103
    From:
    Sent:
    To:
    Subject:
    [email protected]
    Tuesday, January 26, 2010 4:09 PM
    secretary
    Public Comment Form
    Below is the result of your feedback form. It was submitted by
    ([email protected]) on Tuesday, January 26, 2010 at 16:08:32
    commenter_subject: Regulation of Retail Forex
    commenter_comments: The proposal to increase margin requirements for
    the retail Foreign Exchange market is a really bad
    idea.
    While it is true that there are many unscrupulous
    retail FX brokers, there are no scammers and
    bucket-shops that are regulated by the CFTC because
    of stringent rules and regulations that must be
    abided by in these firms. FX dealers that are
    truly in the arena to do good business, such as
    FXCM and Alpari, names I am sure you know well,
    offer multiple warnings to their customers that FX
    is incredibly risky and that their entire
    investment may be lost without excellent risk
    assessment and strategy.
    We all know that. My bet is that every FX trader
    has been wiped out at least once or twice while we
    are learning to trade. There is nothing wrong with
    that, as that is what we were told and that is what
    we expected. We go into an account knowing that we
    may lose everything.
    That having been said, there is no protection the
    government can offer the trader- and nor should it
    offer protection to anyone- because we understand
    the rules that apply to FX. I have learned. I
    understand risk management and I do not expect the
    government to bail me out of losing trades. The
    government, in fact, should not be bailing out
    anyone because of a losing trade but we probably
    had best leave that subject for another discussion.
    By reducing the margin offered by retail FX brokers
    by ten times (10X! ! !), this greatly reduces one
    aspect of the market that is benefical for everyone
    involved: liquidity. The FX market is the most
    liquid in the world and is the main reason I am ani0-001
    COMMENT
    CL-04103
    FX trader. There are ways to manipulate the market
    but it takes an enormous and obvious sum of money
    to do that. By broadcasting such manipulations, it
    makes the expected result null and void, as many
    traders see it well before it comes to a head. No
    one can say that about options on stocks or the
    price of oil.
    I would have to severely restrict my trading
    because of some artificial protection by the
    government that is neither necessary nor welcome,
    as would just about every other FX trader I know.
    I would not have the opportunity to learn and get
    better at it. In short, that would not be fair at
    all to us "home-garners."
    I suggest that if you want to look into a real CFTC
    problem, look at the oil market manipulations by
    Goldman-Sachs last year, or the ongoing market
    manipulation in the price of gold by the COMEX.
    No one has ever said that an FX broker who is
    regulated by your body has manipulated markets or
    deliberately taken investors' money because they
    were not aware of the risks. We all know the risks
    and I haven't heard anyone complaining on the
    trader side, except when we make a really
    bone-headed trade that we weren't supposed to make
    in the first place. There is no protection for
    doing stupid things. That is our own fault, not
    the fault of FXCM or Alpari.
    In short, if it ain't broke, don't fix it.
    I am uncertain as to how the proposal ever started
    but it should be abandoned immediately. Don't go
    after the little guy- again- when there is so much
    questionable activity that your Commission should
    be worrying about.
    Stop this proposal now!
    commenter_name: Kevin Sean Raper
    commenter withhold address on: ON
    commenter addressl: 22107 Woodrose Drive
    commenter_city: Katy
    commenter state: Texas
    commenter_zip: 77450i0-001
    COMMENT
    CL-04103
    commenter~hone: 832.423.7680