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Comment for Proposed Rule 75 FR 3281

  • From: Alpari
    Organization(s):

    Comment No: 3839
    Date: 1/25/2010

    Comment Text:

    i0-001
    COMMENT
    CL-03839
    From:
    Sent:
    To:
    Subject:
    lambros klouvidakis
    Monday, January 25, 2010 4:45 PM
    secretary
    Re: Alpari (US) Speaks out about the CFTC Proposal
    Hello,
    Not a good idea, another wall for the haves and the have nots. Chase the big cats and leave alone the retailer. Your
    ideas only cater exactly to those I mentioned. Only the ignorant will agree with you. The smart ones know whats
    going on. Its the biggest cake in the world and people just like to tamper with it--if anything chase the brokers and
    some of their shady regulations---police them not the public...that's what your their for. And not to protect the cake
    from the retailer in order for you guys and the tea party.
    Thanx
    ..... Original Message .....
    From: Alpari (US), LLC
    To:
    [email protected]
    Sent:
    Monday, January 25,2010 4:04 PM
    Subject:
    Alpari (US) Speaks out about the CFTC Proposal
    Alpari (US) Speaks out about the CFTC Proposal
    New CI~C Proposed Rule
    On January 13, 2010, The Commodity Futures Trading Commission (CFTC) released a
    public proposal,
    Regulation of Off-Exchange Retail Foreign Exchange Transactions
    and Intermediaries,
    which imposes new requirements on the U.S. Forex industry.
    The proposal significantly changes the leverage permitted on certain accounts and, if
    passed, would have a drastic effect on retail investors. In the CFTC proposed
    regulation, leverage in retail forex customer accounts would be subject to a 10-to-1
    limitation.
    Currently, the CFTC enforces lOO:1 leverage (a 1% margin requirement)
    to
    open and
    maintain a position on a forex transaction. With the lO:1 leverage proposed, retail
    traders would be subject to a lO% margin requirement. Retail traders would have to
    invest significantly more to place trades of the same size, ultimately resulting in a
    decreased return or loss on invested margin.
    ~
    The risk-reward ratio that is so
    appealing to the average investor today under lOO:1 leverage would no longer be
    available if the proposal is passed.
    The effect of this change can be summarized through the following example:
    Currency
    Price
    Transaction
    Current Margin
    Proposed
    Margin
    Pair
    Quote
    Size
    Requirement at
    Requirement
    at
    100:1
    Leverage
    10:1
    Leverage
    EUR/USD
    L4285
    I standard lot =
    $1,428.5o
    $14,285.oo
    100,000i0-001
    COMMENT
    CL-03839
    l
    Where we stand
    Mpari (US) has always been a strong supporter of ethical and fair business practices
    and the protections offered to traders through industry regulation. However, Mpari
    (US) does not support
    this
    CFTC proposal.
    Mpari (US) believes that this proposal discourages beginners from developing and
    strengthening their trading style. It effectively prevents investors from evaluating
    their own appetite for risk and making personal investing decisions.
    We place a strong emphasis on educating traders to make informed and responsible
    decisions. We believe that, with proper education, it is not necessary for the U.S. Forex
    industry to be subject to these regulations. Only recently have the doors opened for
    retail investors to trade in this market; these doors are effectively closed through the
    proposed rules, once again making the FX market accessible only to financial
    institutions.
    You have a voice
    Our goal is to guide you in understanding the intentions and ramifications of this
    proposal and remind you that, as a retail investor, you have a say in how your
    freedoms are controlled. We believe that this is a decision to be made by the traders,
    not the regulators. You are the largest group who can make these ramifications
    heard.
    We encourage you
    to
    send your comments
    to
    the CFTC during the 6o day period,
    ending on March ~,~,, ~,olo. If you have an opinion on whether the CFTC should
    restrict leverage across the board to lO to 1, we want you to voice it. Send your
    comments to [email protected]
    and include [] Regulation of Retail Forex[] as
    the subject line of the message. Additionally, you can file comments
    online,
    by fax
    at 9o9-418-559a or by
    mail
    to:
    Secretary of the Commission
    Commodity Futures Trading Commission
    Three Lafayette Centre
    1155 alst Street NW
    Washington, DC ao581
    Team
    of Alpari (US)
    14 Wall Street Suite 5H
    New
    York,
    NY 10005
    Tel: 646.825.5760
    Fax:
    646.825.5761
    www.alpari-us.com
    NFA ID: o379678
    *The potential of profit is equal to the risk of loss on all leveraged transactions.i0-001
    COMMENT
    CL-03839
    Risk Warning:
    Trading foreign exchange, commodity futures, options, precious
    metals and other over-the-counter products carries a high level of risk and may not be
    suitable for all investors. The high degree of leverage associated with such trading can
    result in substantial losses, as well as gains. The past performance of any trading
    strategy or methodology is not indicative of future results, which can vary due to
    market volatility; it should not be interpreted as a forecast of future performance. You
    should carefully consider whether such trading is suitable for you in light of your
    financial condition, level of experience and appetite for risk, and seek advice from an
    independent financial advisor, if you have any doubts. Mpari (US), LLC is registered
    with the CFTC as a Futures Commission Merchant and is a member of the NFA
    -
    Member ID: 0379678.
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    Phone: 1-646-825-5760
    Email: [email protected]
    Web: www.alpari-us.com
    14 Wall St., Suite 5H, New York, NY 10005
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