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Comment for Proposed Rule 75 FR 3281

  • From: Marc Fisher
    Organization(s):

    Comment No: 4918
    Date: 2/4/2010

    Comment Text:

    i0-001
    COMMENT
    CL-04918
    From:
    Sent:
    To:
    Subject:
    Marc Fisher
    Thursday, February 4, 2010 3:13 AM
    secretary
    Regulation of Retail Forex
    RIN 3038-AC61
    Hello,
    I've learned of this survey from Gain Capital website. I'd like to
    express my opinion on the matter of regulatory cap on forex leverage as
    a professional trader of futures and for the past 8 years forex
    instruments.
    The first regulation, which limited the leverage to 100:1 made no sense
    in my opinion, because it is mathematically provable that 100:1 leverage
    cannot be profitable and the trader using it will lose money in the long
    term. Leverage has become a marketing tool for forex brokers the appeal
    to customers with limited capital and sometimes intelligence.
    That said, I understand the idea of regulating the leverage to "protect"
    the consumers, however I've always opposed the elimination of choice
    regulations because personal taste should never be questioned if wrong
    choice means only harm to yourself. The problem is that the uneducated
    majority is being exploited by the brokers, however I believe the
    leverage is just a grease for the money making machine and simply
    accelerates things up - in other words the people who need to be
    protected by these regulations will lose money anyway, it will just take
    a little longer. If this seems like an overstatement, try searching
    "forex leverage" on google....the first result is sufficient to educate
    anyone with reasonable intelligence on the matter and protect him/her
    from being cough by the leverage lure.
    The above is my opinion and I'm sure it won't prevent you from imposing
    the regulation anyway, so back to the matter. I'm personally using 1:10
    to 1:20 leverage in my everyday trading and I'm making money
    consistently. Anything beyond that decreases the chance of survival
    without sufficient capital to resolve potential account wipe-outs. I'm
    sure all reasonable investors won't care if you cap the leverage to 1:20.
    1 : 10 limit would force some, including me, to move their investment
    accounts abroad and continue trading with their favorite leverage. In
    todays interconnected world and unprecedented competition, moving to
    other country takes about 15 mins of time.
    The bottom line is, regulation which limits personal choice is always
    evil, if it happens to disturb the group that it's not supposed to
    regulate, they will find a way around it... always...no exceptions.
    I wish you luck with your work,
    Regards,
    Marc Fisher