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Comment for Proposed Rule 75 FR 3281

  • From: Manfred Bartz
    Organization(s):

    Comment No: 3016
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03016
    From:
    Sent:
    To:
    Subject:
    Manfred Bartz
    Friday, January 22, 2010 8:48 PM
    secretary
    Regulation of Retail Forex
    Dear Mr. Stawick,
    I am concerned about the CFTC's proposal to limit Forex leverage to 10:1.
    While this may be well intentioned, aiming to limit risk to a trader, it may have some
    unintended consequences.
    1. For example, brokerages limit damage to the size of the account, so if a trader for some
    reason looses the ability to close his position, at worst it can wipe out the account. At
    high leverage, only a relatively small account is needed to control a reasonable amount
    of currency. Limiting leverage as proposed may lead some traders to increase their
    account significantly, possibly with money borrowed elsewhere, and thus exposing
    themselves to greater risk than before.
    2. Another, obvious consequence of reduced leverage would of course be that traders will
    move their accounts off-shore, e.g. to the UK.
    3. There may also be other unintended consequences, e.g. an erosion of the US's standing
    as the world's 2nd biggest Forex market.
    Please consider not only the concerns raised by traders but also the possible cascade of
    unintended consequences the proposed leverage limit may have.
    Sincerely
    Manfred Bartz