Comment Text:
i0-001
COMMENT
CL-04663
From:
Sent:
To:
Subject:
Christopher Glendinning Miller
Sunday, January 31, 2010 1 :
18 PM
secretary
Re: Regul ati on of Retail F orex - RIN 3038-AC 61
I trade Retail Forex. I am not an American Citizen and will be unaffected by the above directive. My
reason for responding is that I do not want to see regulation introduce to a market that functions
very well without very limited regulation.
I understand the reason for contemplating the introduction of regulation. However the Forex arena
was in no way responsible for what has become known as the 'Credit Crunch'. In fact there is no
way in which the Forex arena could in any way cause something like the Credit
Crunch. Consquently, the regulations will be punishing those who are not responsible for the Credit
Crunch.
Most Retail Forex is traded over the Internet and provided there is Internet connectivity, it does not
matter where the trader or trading platform is located. Many European brokers are now located in
Cyprus where the such regulation as exists in Europe is lightest. Cyprus provides all of the European
protection with the lightest regulation. Brokers like that and it is just great for us consumers.
If you were to introduce regulations as you propose, you would find that many of your brokers
would simply migrate their platforms to jurisdictions that are lightly regulated or not regulated at
all.
You should be aware that many brokers provide leverage at 400:1 and you are proposing 10:1.
Those brokers that are only able to offer 10:1 will lose any edge on the market that they may have.
Business will disappear abroad to those brokers that offer 100:1. America will almost overnight
cease to be a market leader and instantly lose an industry at which it has been at the forefront since
its inception back in the late 1990's.
The UK platforms are different to the US platforms in so far as the origins of the UK market comes
from the world of gambling and bookmaking. The US platforms come from the world of investment.
The regulations being proposed will drive the market away from the world of investment into the
world of gambling and bookmaking. You should note that since in the UKthe Forex arena emanated
from the world of gambling and bookmaking, the contracts are 'illegal' and therefore any winnings
are not taxable as such unless the Inland Revenue can show that it is the trader's 'trade'. The point
is that human ingenuity being as it is, it will not be very long before any regulations that you may
make will be circumvented to allow the broker to set any level of leverage that they see fit,
including 400:1.
Thus by way of summary, if you introduce these regulations, you will almost certainly kill the Forex
arena in the US and drive the industry abroad. That will cause a loss of jobs in the US plus give your
citizens a golden opportunity to avoid the payment of taxes because you will have no control over
the off-shore jurisdictions. Further it will only be a matter of time until your regulations are
circumvented. If your regulations are circumvented, you quite simply lose any creditability youi0-001
COMMENT
CL-04663
might otherwise have. In other words regulations are there to be made for the common good and
are not there for lawyers to become rich by developing methods of circumvention.
I like America and what it stands for. I send you this email because I care about the values you
uphold. Please don't make a mistake by introducing these leverage regulations for Retail Forex.
Regards
Chris
Chris Miller
Alley 054313 AI Garmak 13
AI Karmal 2
AI Yarmuk 01
Damascus
Syria
Mobile number
Mailto:
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+963 (0) 988 695 363
Chrismiller2009~ live.co.uk
christopher.glendinning.miller
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