Comment Text:
9th January 2013
Mr. David Stawick, Secretary
Commodity Futures Trading Commission
1155 21st Street, N.W.
Washington, D.C. 20581
Re: Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and Derivatives Clearing Organizations: (RIN3038-AD88)
Dear Mr. Stawick:
I am writing to encourage the CFTC to advocate for and adopt rules that would:
1. Require FCMs/RFEDs to segregate retail Forex customer funds in the U.S.
2. Make it impossible for one individual to control or access customer funds held in trust at an FCM/RFED.
3. Bring full market transparency and accountability to the Futures and Forex industries by requiring that firms publish a quarterly consolidated balance sheet and income statement.
4. Require all FCMs/RFEDs to employ a top ten accounting firm.
5. Mandate that all customers have the option to "opt out" of granting FCMs/RFEDs unfettered access to invest their customer funds while still allowing those customers to continue to trade.
6. Allow customer margin to be placed in an insured account and require an insurance program be put in place to protect customers from FCM/RFED insolvency and fraud.
7. Allow U.S. Treasury Notes, or other high-grade instruments, to be posted as margin collateral and held in the name of the customer.
In order for the market to operate efficiently there must be confidence and mutual trust, neither of which exists right now as a lasting result of the recent collapses of multiple FCMs. No one else should have to suffer the potential loss of funds from their accounts the way I and thousands of other traders have at PFG Best.
I appreciate the opportunity to comment on this matter.
Yours sincerely
Clare Colreavy
