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Comment for Proposed Rule 75 FR 3281

  • From: Manfred Paeper
    Organization(s):

    Comment No: 1500
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-01500
    From:
    Sent:
    To:
    Subject:
    Manfred
    Thursday, January 21, 2010 2:43 AM
    secretary

    Regulation of Retail Forex ¯ R1N 3038-AC61
    Dear Secretary Stawick,
    I wish to record my strong objection to the proposed CFTC regulation RIN
    3038-AC61 to limit retail Forex leverage to 10:1.
    I firmly believe that the 100:1 leverage available at present, which as
    you know has already been substantially reduced recently is the minimum
    that makes retail forex trading feasible in the USA.
    Since I am not a US citizen I am somewhat indifferent to whether the
    CTFC choose to kill the US retail forex broker industry with such
    legislation since I will simply move all my US held trading accounts
    elsewhere and shake my head at the stupidity of government intervention
    in private enterprise.
    However, I do like the internet infrastructure available in the USA and
    the performance of the trading systems I am obtaining so do not desire
    to be inconvenienced/forced into making the change by foolhardy
    regulations. As it is already I will not be opening up any further US
    accounts due to the continuously moving regulatory goalposts.
    I mean if the ambit is to reduce retail traders from blowing out their
    accounts - well this is likely to accelerate the process since retail
    traders will now be even more likely with their smaller accounts then
    having more of their capital tied up in margin and with an adverse
    market move having insufficient margin remaining hence resulting in a
    margin call much sooner (probably 10x sooner!) than would have been the
    case when trading at 100:1.
    Ignorant retail forex traders will find ways of losing all their capital
    with or without the CTF C's assistance!
    Reduced margin fixes nothing. Educating traders about position sizing
    does. Rather enforce 0.01 lot increment sizes so that small traders can
    position size appropriately.
    Regards
    Manfred Paeper