Comment Text:
To Whom it may concern,
Though I appreciate tightening up the margin system, I do feel that the proposal on the table will create more damage then good in the industry. MF and Peregrine fell do to misappropriate actions internally tampering with customer funds, not do to a lack of a customer or customers meeting a margin deposit that ultimately ruined the FCM. By incorporating this format, you will add pressure on end users of the futures market that utilize them for hedging as well as speculators that provide vital liquidated. In essence taking liquid markets and making them illquid. Also you will see downsizing in the industry with smaller FCM's unable to compete and ultimately shrink the pool of firms to do business with. if you want to tighten up margin deposit then do it in a fair way vs. same day funds or funds in account prior to transacting. Again this is hurting the end users of the market place not to mention the costs that would need to be involved to get the system fully in place. On the FCM level, incorporate a more rigorous reporting process or maybe have tigther oversight on companies that trade aggressively domestically and abroad. Also limit customer deposit allocation in the overnight market. I want customer fund protection. I have been in the futures industry for over 25 years and proudly have taunted how our industry has never had a default until recently. I took that matter very seriously and quesitoned our industry and agree a change needs to be made but not at the expense of the innocent participants who use the markets and follow the rules but at the FCM level who oversees and controls the customer funds. I know I am only one voice but wanted to express my concern. I am a Guaranteed IB with ADMIS and I can make this statement that I truly believe that ADMIS will not default in the same manner as MF and Peregrine has. They are a very conservative company that has been a leader in the futures industry. As a business owner, I am very confident in my relationship with my clearing firm and truly feel that mine and my clients funds are safe. Should you have any questions or comments, please feel free to contact me
