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Comment for Proposed Rule 75 FR 3281

  • From: Steve Cushway
    Organization(s):

    Comment No: 6003
    Date: 3/4/2010

    Comment Text:

    i0-001
    COMMENT
    CL-06003
    From:
    Sent:
    To:
    Cc:
    Subject:
    Steve Cushway
    Thursday, March 4, 2010 12:49 PM
    secretary
    [email protected]
    Regulation of Retail Forex
    To Who It May Concern,
    I have just recently discovered proposed regulatory changes to the use of FOREX leverage. I'd like to
    respectfully provide my opinion on the proposed change from 100:1 leverage availability to a 10:1 standard.
    If this change should take affect, I feel that the FOREX market could be negatively impacted. Small investors who
    are astute and bring experience to the marketplace are likely to become dissuaded from participating due to
    higher minimum requirements and lack of profitable opportunities and strategies. Liquidity and volume for
    FOREX would be likely to dry-up. Lack of liquidity generally results in higher costs which will then be passed
    (absorbed) by those remaining investors active with the new leverage rules. A lack of liquidity may also adversely
    impact and influence other market pricing asset classes such as interest rates on sovereign and corporate debt
    issues, precious metal commodity spot and futures pricing, etc...
    If an investor CHOOSES to modify their leverage down from 100:1 to a risk tolerance that is more appropriate and
    palatable to their objectives, they should have the CHOICE. It should not be mandated, as this would in fact
    hinder the idea of operating a free and fair capital marketplace.
    A dramatic change in how leverage is used, in my opinion will most definitely cause a negative impact on this
    market and potentially other related markets. As the CFTC body continues to perform due diligence on this
    proposal, please consider the long lasting impacts that may come with the adopting and implementing the
    proposed leverage standard.
    Thank you for your time.
    Sincerely,
    Steve Cushway