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Comment for Proposed Rule 75 FR 3281

  • From: James C Bailey
    Organization(s):

    Comment No: 3476
    Date: 1/24/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03476
    From:
    Sent:
    To:
    Subject:
    James Bailey
    Sunday, January 24, 2010 8:58 AM
    secretary
    Fw: Comments regarding CFTC proposal
    yours truly
    James C, Bailey
    ..... Forwarded Message ....
    From: MB Trading
    To:
    [email protected]
    Sent:
    Thu, January 21, 2010 9:37:16 AM
    Subject:
    Comments regarding CFTC proposal
    Dear MB Trading FX Client,
    On January 13, 2010, the CFTC announced proposed new
    regulations concerning retail foreign currency transactions.
    Many of the proposed changes would implement important
    consumer protection regulations, which MB Trading firmly
    favors. However, one of the proposed changes would
    radically lower Forex leverage from 100:1 to 10:1 for all
    NFA and CFTC regulated Forex firms.
    Under the proposed rule, here are some examples based on
    trading 10,000 USD:
    Current Margin
    Proposed Margin
    Currency Pair
    Requirements*
    Requirements
    EUR/USD
    $142
    $1,420
    GBP/USD
    $163
    $1,630
    USD/JPY
    $100
    $1,000
    *Current
    margin requirements based on rates as of January 19th, 2010
    The impact of these new requirements for a FOREX trader
    could be significant. Under existing rules and based on
    present day exchange rates, a $10,000 account could buy or
    short just over 700,000 EURUSD. With the new proposed
    rule, the same account would only be able to buy or short
    Explore the
    MB Trading Difference:
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    award-winning stock trading
    technology, and 24-hr
    support, all at low
    commissions:
    FOREX
    $2.95 per
    100,000 USD traded
    STOCKS
    $4.95 per trade
    up to 10,000 shares
    FUTURES
    $0.95 per contract
    plus exchanged fees
    OPTIONS
    $0.95 per contract
    No minimumi0-001
    COIMMENT
    CL-03476
    70,000 EURUSD, significantly impacting the results of the
    trade.
    MB Trading recognizes the importance of regulation that
    strengthens industry oversight. We agree with policing and
    regulating the industry, as was Congress' intent when
    empowering the CFTC to create additional rules. However,
    we don't agree with policies that might clearly disadvantage
    firms in the United States which in turn disadvantage you,
    the client. We encourage you to voice your individual
    opinion directly to the CFTC. The Public Comment Period is
    open for 60 days from the date of publication, which was
    January 13, 2010. You may find the entire draft proposal
    here: CFTC.Gov
    and you may contact the CFTC directly by
    sending an email to [email protected]
    with "l~egulation
    of I~et;,il I=ore×
    ''
    in the subject line.
    Want to know more about
    MB Trading?
    Visit our website.
    Thank you for your suppo~.
    Ross Ditlove
    CEO
    MB Trading
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    Disclosure:
    Securities products are offered through MB Trading, member FINRA, SIPC. MB Trading Futures, Inc. (MBTF) is CFTC registered
    FCM and member of NFA. MBTF offers execution and settlement services for futures based products, as well as offer off-exchange
    foreign currency (FOREX) products through MB Trading. Trading in futures, options and forex is speculative in nature and not
    appropriate for all investors, investors should only use risk capital when trading futures, options and forex because there is always
    the risk of substantial loss. Account access, trade executions and system response may be adversely affected by market
    conditions, quote delays, system performance and other factors.
    MB Trading
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