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Comment for Proposed Rule 75 FR 3281

  • From: Nick Pandiscio
    Organization(s):

    Comment No: 5207
    Date: 2/8/2010

    Comment Text:

    i0-001
    COMMENT
    CL-05207
    From:
    Sent:
    To:
    Subject:
    Nick Pandiscio
    Monday, February 8, 2010 3:15 PM
    secreta ry < secretary@ C FTC. g ov >
    Regulation of Retail Forex
    I am writing to oppose the proposed 10:1 leverage limit on retail foreign exchange trading.
    Although this may seem like it would protect the small investor, in reality it limits our options by
    requiring a larger account deposit.
    Traders protect their equity in leveraged accounts through reasonable position sizing. For example,
    if I wanted to risk no more than $100 per trade I could do so by trading either a $10,000 position
    size with a 1% stop loss or a $100,000 position size with a 0.1% stop loss depending on my time
    frame and market volatility. I manage risk by managing the trade.
    Under your proposed requirements, I would need to have $10,000 deposited in my forex account
    to trade a $100,000 lot size (instead of the $1,000 I must have deposited now.) This hurts me
    because it does not allow me to diversify risk as well among multiple asset classes (right now I
    could have that extra $9,000 available to trade in equities or futures, which allows me to diversify
    among non-correlated asset classes.)
    I urge you to reconsider this decision. It would hurt small traders like me, while giving large hedge
    funds and investment banks a bigger advantage in the market.
    Thanks,
    NNick Pandiscio