Comment Text:
i0-001
COMMENT
CL-05653
From:
Sent:
To:
Subject:
Attach:
[email protected]
Monday, March 1, 2010 4:51 PM
secretary
17 CFR Parts 1, 3, 4, 5, 10, 140, 145, 147, 160, and 166 Regulation of Off-Exchange Retail
Foreign Exchange Transactions and Intermediaries
N FAproposed Ru lema king 20100301. doc
Please consider the attached comments. Thank you.
Daryl MercerMarch 2, 2010
P.O. Box 11202
Bainbridge Island, WA 98110
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21 st Street NW
Washington, DC 20581
Dear Sirs:
I am a forex trader and am writing to provide my comments and express my concerns
about the proposed leverage reductions being considered by your organization. I believe
the proposed changes will profoundly affect my profession.
I have dedicated myself to trading and have spent a considerable amount of time and
money to become a proficient trader. I now trade full-time.
I understand and appreciate the risks associated with the higher leverage typically offered
by forex brokers. Obviously, leverage can work for you or against you, depending on
your knowledge of the market, your application of proper money management principles,
and the integrity of your brokerage firm.
By lowering the leverage to the proposed 10% level, you are effectively requiring me to
substantially increase the funds in my unprotected trading accounts to support the same
level of trading and profitability. These substantially larger cash reserves are not
protected by the SIPC or any similarly chartered organization and can be completely lost
should the broker go out of business.
I understand and appreciate that your organization has responsibilities to try to keep the
playing field as level as possible and I appreciate the changes you have made to clean up
the brokerage side of the business. I suggest that you also require brokerages to no
longer treat an individual with a trading account as an unsecured creditor. They should
be required to structure their brokerage in such a way that they cannot use deposited
funds as their own piggy bank, similar to what stock brokerages are required to do. For
the most part, the brokerages that I have dealt with seem to be doing a much better job.
Thank you for that. If I enter into a bad trade, I have nobody to blame but myself for the
outcome and I can accept that and use the information from that trade to learn and
improve. However, I have virtually no power to correct the situation if my broker is
treating me unfairly.Finally, please recognize that I am a professional traders and take my trading very
seriously. I do not require, nor do I desire, the government to "protect" me by enacting
the rule changes that you have proposed. It will not accomplish its intended goal. It
seems counterintuitive that, if over the age of 21, I am allowed to completely destroy my
financial life and that of my family in a casino where the odds of just breaking even are
impossibly large, while at the same time, the government feels compelled to protect me
as a professional trader from myself.
Please reconsider your proposed rulemaking. Thank you for your consideration.
Sincerely yours,
DarylMercer
