Comment Text:
i0-001
COMMENT
CL-02708
From:
Sent:
To:
Cc:
Subject:
Robert Manuse
Friday, January 22, 2010 1:10 PM
secretary
Sanchez, Peter ; Stawick, David
; Smith, Thomas J. ; Bauer,
Jennifer ; Penner, William ;
Cummings, Christopher W.
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,
¯ 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.
¯ 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.
¯ 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 volumes 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.i0-001
COMMENT
CL-02708
The bottom line is that OTC Retail Forex trading is NOT Futures
trading. Please do not try to treat it as such!
PLEASE IMMEDIATELY STRIKE YOUR PROPOSED 10-1 LEVERAGE LIMITATIONS.
Don't let proposal R1N 3038-AC61 become an expensive lesson in
unintended consequences ....
Thank you.
Robert Manuse
