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Comment for Proposed Rule 75 FR 3281

  • From: Tim Skallet
    Organization(s):

    Comment No: 473
    Date: 1/19/2010

    Comment Text:

    i0-001
    COMMENT
    CL-00473
    From:
    Sent:
    To:
    Subject:
    Tim Skallet
    Tuesday, January 19, 2010 10:50 AM
    secretary
    Regulation of Retail Forex
    RIN 3038-AC61
    Please remove the 10:1 leverage limitation. I'm all for anti-fraud authorities and NFA registrations, but
    the only thing this leverage reduction will do is force MANY retail forex traders to open "overseas"
    accounts in search of more flexible leverage, in which case may drive that business to unregulated
    dealers, where there is even less or no oversight.
    Who will gain from this? Most likely the non-U.S, brokers.
    GFT, Oanda, IBFX, Gain Capital, FXCM, FX Solutions, FXDD, PFG Best and CMS Forex consider
    that if the proposal passes:
    - 90% of the account will go offshore, mostly to the United Kingdom
    - Thousands of high educated jobs will be lost
    - An industry worth over $1 billion gone, loosing millions in taxable revenue.
    - The proposal does not fix fraud, the subject the rule tries to adjust. Battle against unlicensed
    FDMs
    and IBs fix the fraud, not 10 to 1 leverage.
    - 100 to 1 leverage is very popular. Traders simply will not accept 10 to 1 leverage.
    - Unregulated dealers from around the world
    will also
    benefit.
    Conclusion: Thousands of jobs lost when unemployment is at 10%, consumers more vulnerable to
    fraud, and the United States tosses away one of the most promising export industries.
    Signed,
    Tim Skallet