Comment Text:
i0-001
COMMENT
CL-00121
From:
Sent:
To:
Subject:
Roberto Azank
Friday, January 15, 2010 8:02 PM
secretary
Regulation of Retail Forex
Dear Sirs:
I am writing in regards to the changes proposed in RIN 3038-AC61.
Although I favor much of the changes proposed to insure the public
safety when dealing with all peoples involved in handling other
peoples investment (even though it means I'll have to take the exam
and register and pay the yearly dues), I do have serious objections
to the motion to limit leverage to 10:1.
Clearly it will benefit new traders, but it will devastate trading
techniques that we have developed over years. These techniques are
meant to distribute risk over many different forex pairs, trading
small lots, and expecting average small gains based on usual market
movement. This cannot be implemented with the proposed small
leverage. It will simply cease to be a way of trading, which will
force me to look into moving my account and those of my clients to a
broker outside the US. There is really no choice since the trading
program will be dead the moment this regulation goes into effect.
My clients have relatively small accounts, about $5000, and without
leverage of 100:1 there would not be enough buying power that would
allow diversifying the risk and going for small gains.
Please reconsider the issue. Having to move the accounts overseas
makes trading far less secure for the public, drains capital from the
US and certainly kills some industry jobs.
Perhaps you can find a way to regulate in favor of safety, without
forcing us to leave our US brokers, the US legal system safety that
would not be available with an overseas broker, and the safety of
having all industry members register with the NFA. Obviously if we do
business overseas your motion of having us register with the NFA
loses ground, since those brokers will not demand registration to
allow us to trade clients accounts. All in all it sounds that it
would be doing much more harm than good.
Perhaps a stringent wording warning new traders might educate them so
they can use the tools of the trade safely.
Thanks for your attention to this matter.
Sincerely
Roberto Azank
From uploaded file 121_BPACConsole.txt:
1/4/2010 3:55:29 PM... 23 change(s) to BPAC list.
1/4/2010 4:02:59 PM, True... 23 change(s) to BPAC list.
