Comment Text:
i0-001
COMMENT
CL-04730
From:
Sent:
To:
Subject:
Robert Danielson
Monday, February 1, 2010 1:12 PM
secretary
Regulation of Retail Forex
TO: [email protected]
Subject: Regulation of Retail Forex
This message is to inform you of our opinion regarding the proposed changes to margin requirements
for forex trading and the expected impact on our company. We are a new business with a business plan
model which forecasts 8 to 10 new employee hires in the next 12 months. The new margin requirement
proposal of 10:1 would greatly increase our capital costs, which when applied to our model, cuts our
new hire forecasts from 8-10 to 1-2.
Our business does not look at the 400:1 or 500:1 brokers. Our model runs at a 100:1 margin
requirement. We have plugged in a 50:1 margin requirement and believe we can still operate at this
level. However at 10:1 it not only forces us to eliminate up to 8 new jobs, it also forces us to look off-
shore for better terms. While we understand the need for regulatory restrictions, we believe the
proposed attempt to lower margin requirements to 10:1 is extremely detrimental to businesses with good
financial models and structured operating procedures. Please do not hamper jobs and economic growth
by strangling us with restrictions that are anti-stimulus.
We ask you reconsider this proposal by defining a margin requirement level that accomplishes the
regulatory goals without hampering jobs and economic growth.
Thank you for considering our comments,
Robert Danielson
rdani el son.usa@gmail, com