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Comment for Proposed Rule 75 FR 3281

  • From: Michael Catmull
    Organization(s):

    Comment No: 3030
    Date: 1/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03030
    From:
    Sent:
    To:
    Subject:
    ODS-Michael
    Friday, January 22, 2010 9:24 PM
    secretary
    Regulation of Retail Forex
    To whom it may concern:
    I am writing to you in opposition to the i0:i leverage proposed restriction. My guess is that a relative few retail
    Forex traders have caused this proposal to come to the forefront of the CFTC. As with most government
    intervention for the minority, the unintended collateral damage for the responsible, educated majority is far
    worse the perceived benefits
    This
    10:1
    leverage will have negative impact to the majority of successful traders that are actually making money
    in the Retail Forex Market. I say the majority because it would not be a thriving vehicle for trading if the
    majority of traders were losing money. I can envision at least 2 negative unintended consequences:
    More money would be at risk for all those successful traders that are using their current leverage
    appropriately.
    This will prohibit many (like me) from ever realizing my dream of being independent of economic
    downturns and being subject to an employer. I spent several months paper trading before I started to
    trade. This involved me making a lot of mistakes (i.e., resetting my paper trading account) along the
    way but has proved to be most beneficial after I went live with real money.
    Instead we need to be proactive vs. reactive. Enforce education and certification for retail traders. As I
    indicated, I paper traded for several months before I had any sort of confidence I could trade using "real"
    dollars. This education could include some of the following:
    ¯
    Required courseware that certifies a budding retail trader understands the risks of trading Forex using
    existing leverage levels
    ¯
    Videos show both the "upside" of a good responsible trading and the "downside" of ignorant
    uneducated trading.
    ¯
    Require Paper Trading results for a I. If a retail trader requires a reset of their account, they must start
    over. The retail trader must exhibit they can make a certain percentage (e.g., 5%-10% - better than they
    can do in the bank) on their account before they are certified to trade live.
    would suggest 2 types of paper trading accounts: pre-certification and certification
    ¯ Apre-certification
    account would be free and could be reset as often as desired
    ¯ A certification
    account would require a fee (say $50-$100 or some percentage of the
    starting capital) for the initial "funding" and any resets that follow during the
    certification period. This would force the budding retail trader to take the paper trading
    seriously.
    All of the above puts the responsibility back on the retail trader and allows other successful traders to continue
    being successful. If after going through the above steps and the retail trader still fails then they probably were
    not following what the exhibited during their education and certification process.
    A collateral benefit could be a spawned educational industry for educating (not selling) Forex trading as a viablei0-001
    COMMENT
    CL-03030
    method of generating additional income and tax revenue for government.
    If you restrict the leverage you have to potential of adding to the current unemployment rolls for those that will
    no longer be able trade using 10:1 leverage.
    Thanks,
    MichaelCatmull