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Comment for Proposed Rule 75 FR 3281

  • From: Roman Startsev
    Organization(s):

    Comment No: 2714
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-02714
    From:
    Sent:
    To:
    Subject:
    Roman Startsev
    Friday,
    January 22, 2010 1:17 PM
    secretary

    'Regulation of Retail Forex'
    the identification number RIN 3038-AC61
    Dear Sir/Madam,
    I just received the message from IBFX regarding your proposal - to reduce the overall leverage from 100:1 to 10:1 basis. I
    would like to state some comments regarding this proposal.
    Despite I think that the choice of leverage is up-to final customer, many of these 'clients' do NOT understand that the risk
    even 100:1 is too large. This huge level of leverage makes these clients want to get xxx% profit per short period; then they
    risk too much and finally they lose their deposits. This method of thinking in any business is too dangerous. Not only for
    clients, but also for family members (they lose not also their only money, but the money of all family members)
    I think your initiative is right: the lesser the leverage, the more chances the client have to stay in trading business. 10:1
    leverage is more than enough.
    Regards, Roman.
    ..... Original Message .....
    From: Interbank FX [mailto:[email protected]]
    Sent: Thursday, January 21, 2010 5:02 AM
    To: Roman Startsev
    Subject: CFTC's Proposal of Leverage Changes: How You Can Help
    Interbank FX
    Interbank
    FXheader_gradient.png>
    Questions? Contact Us


    Dear Valued Customer,
    As many of you are aware, the U.S. Commodity Futures Trading Commission (CFTC) announced on January 13, 2010 that it
    is seeking public comment on proposed regulations concerning retail Forex trading.
    As part of the proposed regulations, it is stated: "leverage in retail forex customer accounts would be subject to a 10-to-1
    limitation," which means 10:1 leverage would be the maximum amount allowed for all F orex traders in the U.S.
    An example of how the proposed regulatory restrictions would affect a major currency pair appears below:
    Maximum Leverage under Current Regulations Maximum Leverage under Proposed CFTC Changes
    USD/CHF
    USD/CHF
    100:1 leverage (one percent) 10:1 leverage (10 percent)
    1
    lot (100,000)
    1
    lot (100,000)
    Margin requirement: $1,000 Margin requirement: $10,000
    We stand behind the belief that you should be given the freedom and right to choose the amount of leverage that is
    appropriate for your individual desired risk, and that this basic principle of 'choice' is in jeopardy by the proposed CFTC
    regulations.i0-001
    COMMENT
    CL-02714
    If you feel strongly about the proposal, ~ve encourage you to help determine the outcome of these proposed regulations. You
    can help make an impact by sending comments directly to the CFTC at: [email protected].
    Please include 'Regulation of Retail Forex' in the subject line of your message and the identification number RIN 3038-AC61
    in the body of the message.
    You can also submit your comments by any of the follo~ving methods (include above ID number):
    *
    Fax: (202) 418-5521
    *
    Mail: David Sta~vick, Secretary Commodity
    Futures Trading Commision 1155 21st Street, N.W.,
    Washington, DC 20581
    *
    Courier: Use the same as mail above.
    In the upcoming days, Interbank FX and the rest of the U.S. Forex Dealer Coalition ~vill be releasing a more formal opinion
    about the proposed changes. Please feel free to read further details about the regulation on the CFTC ~vebsite by clicking here
    .
    In the interim, ~ve encourage you to voice your
    opinions to the CFTC and your local U.S. representative.
    As al~vays, ~ve ~vant the best for our traders. We hope you'll join forces ~vith us to prohibit the proposed leverage
    requirements.
    The Interbank FX Team










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    Trading in the off exchange retail foreign currency market is one of the riskiest forms of investment available in the financial
    markets and suitable for sophisticated individuals and institutions. The leveraged nature of FX trading means that any market
    movement ~vill have an equally proportional effect on your deposited funds. This may ~vork against you as ~vell as for you.
    The possibility exists that you could sustain a total loss of initial margin funds and be required to deposit additional funds to
    maintain your position. If you fail to meet any margin call ~vithin the time prescribed, your position ~vill be liquidated and
    you ~vill be responsible for any resulting losses.i0-001
    COMMENT
    CL-02714