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Comment for Proposed Rule 75 FR 3281

  • From: Robert Danielson
    Organization(s):

    Comment No: 4730
    Date: 2/1/2010

    Comment Text:

    i0-001
    COMMENT
    CL-04730
    From:
    Sent:
    To:
    Subject:
    Robert Danielson
    Monday, February 1, 2010 1:12 PM
    secretary
    Regulation of Retail Forex
    TO: [email protected]
    Subject: Regulation of Retail Forex
    This message is to inform you of our opinion regarding the proposed changes to margin requirements
    for forex trading and the expected impact on our company. We are a new business with a business plan
    model which forecasts 8 to 10 new employee hires in the next 12 months. The new margin requirement
    proposal of 10:1 would greatly increase our capital costs, which when applied to our model, cuts our
    new hire forecasts from 8-10 to 1-2.
    Our business does not look at the 400:1 or 500:1 brokers. Our model runs at a 100:1 margin
    requirement. We have plugged in a 50:1 margin requirement and believe we can still operate at this
    level. However at 10:1 it not only forces us to eliminate up to 8 new jobs, it also forces us to look off-
    shore for better terms. While we understand the need for regulatory restrictions, we believe the
    proposed attempt to lower margin requirements to 10:1 is extremely detrimental to businesses with good
    financial models and structured operating procedures. Please do not hamper jobs and economic growth
    by strangling us with restrictions that are anti-stimulus.
    We ask you reconsider this proposal by defining a margin requirement level that accomplishes the
    regulatory goals without hampering jobs and economic growth.
    Thank you for considering our comments,
    Robert Danielson
    rdani el son.usa@gmail, com