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Comment for Proposed Rule 75 FR 3281

  • From: Dexter Brown
    Organization(s):

    Comment No: 2314
    Date: 1/21/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02314
    From:
    Sent:
    To:
    Subject:
    Dexter Brown
    Thursday, January 21, 2010 9:59 PM
    secretary
    STRONGLY OBJECT TO 10-1 LEVERAGE LIMIT IN REGULATION OF
    RETAIL FOREX PROPOSAL RIN 3038-AC61
    Attn : David Stawick, Secretary, CFTC
    and ALL CFTC policymakers:
    As a non-affiliated US-based Retail FX trader, please note for
    the record that I am STRONGLY OPPOSED to the 10-1 leverage limit
    as proposed in RIN 3038-AC61 relating to the Regulation of
    Retail Forex.
    Counter-productive effects
    This senseless limit would in NO way protect, aid or benefit me
    but rather would greatly harm me since this restriction, if
    passed,
    5022 would require that I submit substantially more margin-funds
    into non-protected, non-FDIC insured, non-SIPC eligible
    accounts, actually exposing me to increased risk in the event of
    bankruptcy of my Forex Broker.
    5022 would NOT divert my business into regulated-Futures trading
    (as the CFTC is probably hoping), but rather would cause me to
    seek an unreliable, higher-risk offshore FX broker to trade
    through, whose practices might be questionable.
    5022 would eliminate one of the greatest benefits of trading
    Forex : My ability to efficiently deploy my own trading capital
    in the way that I choose.
    Lower FX vols require far greater leverage
    FX volatilities are generally substantially lower than in the
    Equities or Futures market. Therefore, significantly more
    leverage is required simply to capture equivalent trading
    opportunities.
    Nanny not needed
    I do not want the CFTC to treat me like a child and dictate how
    I should trade. While 100-1 leverage is available to me - should
    I choose it - I am never forced to use it.
    The bottom line is that OTC Retail Forex trading is NOT Futures
    trading. Please do not try to treat it as such!i0-001
    COMMENT
    CL-02314
    PLEASE IMMEDIATELY STRIKE YOUR PROPOSED 10-1 LEVERAGE
    LIMITATIONS.
    DonS019t let proposal RIN 3038-AC61 become an expensive lesson
    in unintended consequencesS026.
    Thank you.
    DexBiz
    Get your own "800" number
    Voicemail, fax, email, and a lot more
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