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Comment for Proposed Rule 75 FR 3281

  • From: Nathan Wyss
    Organization(s):

    Comment No: 3002
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03002
    From:
    Sent:
    To:
    Subject:
    Nathan Wyss < nathanwyss@ hotmail.com >
    Friday, January 22, 2010 8:10 PM
    secreta ry < secretary@ C FTC. g ov >
    Regulation of Retail Forex
    RE: RIN 3038-AC61
    Attention David Stawick,
    I am writing you to express my extreme disapproval of the proposed rule changes you want to make to retail
    FOREX trading. I cannot imagine the real reason you want to do this. I assume you are telling people the reason
    is you want to make it safer for the average person to trade FOREX by lowering the available leverage, thus, in
    theory, lowering the maximum amount of money one can lose while trading. While it may be true that there are
    citizens of the U.S. who do not understand the concept of leverage well enough to be trading, yet these people
    trade anyway and many of them lose money. Where do I start on why this plan is so wrong?
    1. People who trade without fully understanding leverage will lose money because they most likely do not
    understand how to be a successful trader. Leverage is just one small piece of the pie. Even if you lower leverage
    to 10:1, and they some how still have enough money to fund their accounts to trade at that leverage, they will still
    lose their money for a million other reasons.
    2. Taking away my freedoms and all other traders' freedoms to protect people who should not be trading in the
    first place is anti-capitalist and anti-american. It's the equivalent of prohibiting stores from selling sharp knives
    because once in a while some one cuts themselves by behaving irresponsibly.
    3. Traders will be more likely to experience more margin calls at 10:1 leverage than 100:1 leverage for the simple
    fact that most retail traders do not have $100,000 to fund an account with to trade the same way they were
    trading at 100:1 leverage with a $10,000 account. This new rule would punish many currently responsible and
    profitable traders because of this issue.
    4. You would take away the main income and side income of tens of thousands if not hundreds of thousands
    Americans by stripping them of their ability to trade they way they are trading right now. Not only would traders
    lose their income, but brokers would go out of business, or at best downsize, do to the sudden lack of business
    and thousands of people would be put directly out of work.
    5. Some traders may move their accounts off shore to continue to trade. But the mass reduction in trading will
    impact the markets' behavior and could render many trading systems ineffective. Traders would only figure this
    out after many consecutive losses. That translates into lost money, as well as the lost time and effort developing
    those now useless trading systems.
    In the first paragraph I said I cannot image the real reason you want to make these rule changes, specifically the
    leverage reduction. I say this because these 5 points I mentioned above are quite obvious. I doubt you rode the
    short bus to school while wearing a helmet. I'll bet you are of above average intelligence. I'd also bet you realize
    the impact of reducing the maximum leverage in retail trading would be catastrophic to the industry, at least in the
    US. Much like the "First In First Out" rule, the reduced leverage does nothing to help us retail traders. Unlike the
    "First In First Out" rule, which is reduced to an annoyance by clever work-arounds, reduced leverage will most
    likely destroy my ability, along with countless other traders' ability, to continue trading.
    What is the real reason you want to reduce leverage? Do you have even one letter or email to support this rule
    change? Who exactly supports this rule change and why?
    Sincerely,
    Nathan Wyss
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