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Comment for Proposed Rule 75 FR 3281

  • From: Fred Zhang
    Organization(s):

    Comment No: 120
    Date: 1/15/2010

    Comment Text:

    i0-001
    COMMENT
    CL-00120
    From:
    Sent:
    To:
    Subject:
    huayu zhang
    Friday, January 15, 2010 8:00 PM
    secreta ry < secreta ry@ C FTC. g ov >
    Regulation of Retail Forex
    RIN 3038-AC61
    Dear Secretary,
    As a FX trader with years of experience, I am fully against the recent proposal to limit
    leverage to 10:1. Here's my reason.
    Currently I'm being successful trading FX with dealers providing 50:1 to 200:1 leverage,
    but I only use around 7:1 to 11:1 leverage in all of my 6 accounts. The big differences
    between available leverage and used leverage in each account assure that all my
    positions are safe from forced liquidation under any volatile market movements.
    But now with the 10:1 leverage, I will lose the preferred buffer and my positions will be
    in much bigger danger to be liquidated by dealers if there's market news hit the
    wire. Because if the leverage will be limited to such a low level, I'm automatically being
    forced to use greater portion of available leverage and much easier to getting a margin
    call. Even I did all I can to limit my trading risk, such a rule will put many individual
    traders like me in worse situation.
    If the proposal to become rule, I, with many traders I know, will close accounts in U.S.
    and flee overseas. Losing protection from domestic regulator is the last thing we want
    trading FX, but 10:1 leverage cap is just untradeable.
    Regards.
    Fred Zhang
    725 N 92nd CT. Apt404
    Omaha,NE 68114
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