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Comment for Proposed Rule 75 FR 3281

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  • From: Peter Grossman
    Organization(s):

    Comment No: 3087
    Date: 1/23/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03087
    From:
    Sent:
    To:
    Subject:
    Peter Grossman
    Saturday, January 23, 2010 12:18 AM
    secretary
    Regulation of Retail Forex
    Dear Secretary,
    About four years ago, I had a decent size retail forex account with Refco FX, maybe about 35K or so; all my
    eggs were in one basket.
    Refco Fx went bust and I settled for about 21 cents on the dollar; not a pretty picture.
    Today, I have four separate small FX accounts with different brokers; I never let any one these account grow
    above 12K.
    Instead, I skim profits when needed for income and savings. This is how I distribute my "rogue broker" risk;
    multiple accounts with anywhere from 100:1 to 100:2.5 leverage.
    This high leverage allows me to maintain and trade these multiple accounts with relatively low balances, never
    exceed usage 10% account equity for any one trade, and risk no more 1-2% loss for any trade.
    This is how I manage trade risk and broker risk. I keep the risk small and spread it around. 1-2% leverage is
    essential for such a program.
    By reducing margin, funds become consolidated into fewer larger accounts, into fewer larger brokers and
    into fewer larger banks, until there are only a few big players left to distribute risk.
    Eventually, too big to FAIL will become too big to BAIL!
    I subsist on small accounts and managed leverage; the risk is to me and my small accounts, Not the entire
    financial system.
    Sincerely,
    Peter Grossman