Comment Text:
i0-001
COMMENT
CL-04105
From:
Sent:
To:
Subject:
Vishnu Eschner
Tuesday, January 26, 2010 4:19 PM
secretary
Regulation of Retail Forex
David Stawick, Secretary
Commodity, Futures Trading Commision
1155 21st Street, N.W.,
Washington, DC 20581
RE: RIN 3038-AC61
Regulation of Retail Forex
Dear Mr. Secretary,
As a self-taught retail forex trader, I have spent the better part of the last five years gaining
the knowledge and experience to become profitable. Every Forex broker I have reviewed or
worked with has clearly posted information regarding the risks associated with retail trading,
specifically on margin. Most broker websites are dedicated to educating the retail trader and
have well-publicized, informative articles on money management techniques and the use of
margin.
Your offices have also done a particularly effective job of protecting the retail Forex trader.
The due-diligence required before going into the retail Forex business quickly leads one to
conclude that it is wise to use a broker under the jurisdiction of the CFTC.
Despite the confidence I have come to hold in the CFTC, I am opposed to your current
proposal to limit retail traders to a 10% margin requirement. [RIN 3038-AC61] The primary
effect would be to eliminate the retail trader from the business, putting Forex squarely into the
hands of some of the institutions that have not recently shown the same fiscal acuity as most
successful small-business persons.
Myself and thousands like me who have built legitimate, productive enterprises would be
forced out of business by regulation whose only upside seems to be that it makes the market
safer for the few people who have not prepared themselves before jumping in. These are
precisely the individuals whom we want to discourage from trading Forex.
Those who don't prepare before beginning a business venture naturally move-on, a bit more
savvy, and possibly sadder. This unfortunate fact cannot be regulated out of the marketplace.
We wouldn't place limits on the amount of inventory a corner grocery store can carry, the
number of tools a contractor can own, or clients a consultant can carry. These make-or-break
decisions are part of any healthy enterprise.
For our country to regain its rightful place in the world market, the small business owner,
including the retail Forex trader, will be asked to shoulder a healthy part of the burden. In our
business models we employ office help, utilize accountancy, internet, and computer services,i0-001
COMMENT
CL-04105
rent real estate, travel, educate ourselves, etc. Our tax liabilities are accounted and reported
by the responsible US brokers through whom we trade. Limiting the margin we can trade to
10% would impact profits to the degree that most of us would be forced out of business.
Limiting the margin to 10% for the retail Forex trader would effectively hobble one of the
healthier sectors of the economy--and one that pays its fair share.
Thank you for considering my point of view.
Respectfully,
Vishnu Stephen Eschner
Please do not publish or publicize my contact information. I offer it solely in case you need to
verify or contact me. Thank you.
1755 McAllister St.
San Francisco, CA 94115
415-518-8423
