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Comment for Proposed Rule 75 FR 3281

  • From: Duane Megonigle
    Organization(s):

    Comment No: 1401
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-01401
    From:
    Sent:
    To:
    Subject:
    [email protected]
    Thursday, January 21, 2010 12:09 AM
    secretary
    Regulation of Retail Forex
    RE: RIN 3038-AC61
    My stand on the current CFTC Proposed Regulation of Retail Forex:
    I encourage the CFTC [] s effort to reign in the actions of unscrupulous
    currency dealers, IB [] s and money managers. If you want to manage money,
    or execute authority on a clients account you should be registered. I
    also believe the capital requirements are necessary and ultimately weed
    out weak dealers from the business. Perhaps this will limit consumer
    choice to a few big dealers, but I believe the protection offered is
    worth it.
    Regarding margin requirements, I am adamantly opposed to the proposed
    restrictions. I believe in personal choice, and personal responsibility.
    If you do not understand the damage you are a capable of doing through
    flae use of high leverage, you should not be trading. It is your
    responsibility to understand the market you are participating in,
    practice diligently and protect your capital before placing a single
    dollar at risk. If you txade without regard to the risks, and lose your
    shirt, it[] s your fault. Regulating the leverage available across the
    board punishes everyone in the name of protecting the lowest common
    denominator among traders, and that frustrates me. All reputable FCM,
    IB, CTA or CPOs I know go out flaeir way to warn lxaders about the risks
    of trading on margin. Unfortunately, even if you lead a horse to water
    you can't make it drink. Even at 10:1 leverage there will be traders who
    blow out their accounts, some people never learn. I do not want my
    choice of leverage limited in the name of consumer protection. There are
    many retail lxaders who have jumped ship overseas already, and I may
    follow flaem if these regulations are enacted.
    I believe these proposed changes, if enacted will actually have a
    negative net affect on retail currency txaders. Instead of protecting
    flae consumer, the CFTC [] s actions will drive small volume retail traders
    to overseas dealers where leverage can be as high as 700:1! There are
    also unregulated dealers overseas who will take advantage of retail
    lxaders seeking 100:1 leverage. The Foreign Exchange Dealers Coalition
    is correct in their statement saying:
    []Unregulated dealers from around the world will also be the
    beneficiaries of the 10 to 1 leverage rule. These unregulated forex
    dealers don[]t have to worry about capital requirements, risk management
    models, marketing ethics, dealing practices or even returning a
    customer [] s funds. These dealers will be out of the reach of the CFTC and
    flaey will thrive. []
    Sincerely
    Duane Megonigle
    Retail Trader
    FXDC Statement against proposed 10:1 leverage restrictions