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Comment for Proposed Rule 75 FR 3281

  • From: Robert Lowder
    Organization(s):

    Comment No: 4821
    Date: 2/3/2010

    Comment Text:

    i0-001
    COMMENT
    CL-04821
    From:
    Sent:
    To:
    Subject:
    Robert Lowder
    Wednesday, February 3, 2010 12:36 PM
    secretary
    Comment on Proposed Regulations Regarding Retail FOREX Transactions
    David Stawick, Secretary, Commodity Futures Trading Commission
    Dear Mr. Stawick,
    Please consider my comments regarding past and proposed regulations for Forex retail transactions. In
    2007 1 began trading the Forex following MASSIVE losses in the precious metals market with a well
    known firm whose sterling reputation is applicable only to fools. During the crash in 2006 the broker
    would not take calls. Thus my seemingly endless attempts to close trades were in vain.
    Forex trading with a representative of a firm was very helpful and I made money and lost money.
    Eventually I lost all of my account. Not to be discouraged I reloaded and did it again, and again. Still
    not persuaded to leave the market I research more brokers/dealers and studied margin, indicators and
    ideas of brokers who are successful. May 2009 1 emptied my account again and determined to trade
    only in "demo" mode until I was successful before reloading an account.
    My suggestions are:
    ¯ require full financial disclosure by brokers
    ¯ require disclosure and evidence that traders have received training in margin and rollover charges
    ¯ REQUIRE traders to certify using a demo account that they understand margin and rollover
    ¯ allow traders to leverage up to 400:1 if they certify that training in margin and rollover charges
    has been practiced by them
    ¯ allow hedging and exit of trades in any order regardless of when placed
    Implementing these few suggesting will return the freedom to trade as skill allows. Greed cannot be
    regulated as is evidenced by the financial condition of the treasuries of most countries.
    Some Forex brokers are better than others. They work on the premise of what they can get traders to
    accept, which frequently is detrimental for all concerned. I would never trade with my first brokerage
    house again. But I have found others that are pretty good. None of them are training traders to use
    leverage thoroughly. Some help to identify trends but how a person trades is very individualist. I have
    taken courses and suggest that be done by all new traders. None the less how I trade is an expression of
    who I am. Please do not regulate trading in an attempt to force greed out of the system. Each trader
    must decide what will or will not work for them.
    Risk disclosure statements are now given like airlines presenting emergency procedures on each flight.
    Disclosure does NOT equal proper margin management. Similarly drug and alcohol laws permit an
    individual to determine the level to which they will indulge in the practice. So should Forex trading
    regulations.
    Respectfully,
    Robert Lowderi0-001
    COMMENT
    CL-04821
    Release: 5772-10
    For Release: January 13, 2010
    CFTC Seeks Public Comment on Proposed
    Regulations Regarding Retail FOREX
    Transactions
    The proposed rules follow the passage of the Food, Conservation, and Energy Act of 2008, Pub. L. No.
    110-246, 122 Stat. 1651, 2189-2204 (2008), also known as the "Farm Bill," which amended the
    Commodity Exchange Act in several significant ways. In particular, the Farm Bill: Leverage in retail
    forex customer accounts would be subject to a 10-to-1 limitation. All retail forex counterparties and
    intermediaries would be required to distribute forex-specific risk disclosure statements to customers, and
    comply with comprehensive recordkeeping and reporting requirements.