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Comment for Proposed Rule 75 FR 3281

  • From: John Jagerson
    Organization(s):
    Learning Markets LLC

    Comment No: 1853
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-01853
    From:
    Sent:
    To:
    Subject:
    jj [email protected] on behalf of
    John Jagerson
    Thursday, January 21, 2010 1:39 PM
    secretary
    Regulation of Retail Forex
    In general I feel that more maturity in the forex industry is needed but we don't feel that the new
    leverage ratios are likely to do anything more than drive accounts to overseas dealers.
    A traders can lose everything with 10:1 leverage almost as efficiently as 100:1 leverage. If the CFTC is
    serious about trying to help traders survive and thrive in the forex the real missing component is
    information and transparency.
    Traders would act more rationally if forex dealers were required to disclose at least three things about
    their account holders on average.
    1. What is the average account balance, account lifespan and leverage being utilized.
    2. What is the correlation between the use of high leverage and large losses
    3. What is the correlation between trading frequency and large account losses
    Anyone with any long term experience in this industry knows the answer to these questions - including
    the dealers. But what retail traders get instead is overgeneralized "education," hype and disclaimers too
    obtuse to convey anything practical.
    Baby-sitting traders with account constraints like this will merely drive them into the arms of less
    reputable, pandering and potentially insolvent foreign dealers. Real information, transparency and
    education are the only ways to change behaviors and help traders do better. This proposed rule change
    does none of those things.
    John Jagerson
    Learning Markets, LLC