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Comment for Proposed Rule 75 FR 3281

  • From: Nate
    Organization(s):

    Comment No: 5356
    Date: 2/13/2010

    Comment Text:

    i0-001
    COMMENT
    CL-05356
    From:
    Sent:
    To:
    Subject:
    [email protected]
    Saturday, February 13, 2010 12:22 PM
    secretary

    Public Comment Form
    Below is the result of your feedback form. It was submitted by
    ([email protected]) on Saturday, February 13, 2010 at 12:22:07
    commenter_subject: 75 FR 3281 Forex Leverage
    commenter frpage: 75 FR 3281
    commenter comments:
    To whom it may concern:
    I []m writing to express great concern about the
    proposal seeking to limit leverage in retail forex
    accounts to 10:1. As a professional forex trader
    with a proven track record of successful trading
    through retail brokers, the imposition of this
    limitation in leverage would seriously damage my
    ability to trade successfully. During my typical
    trading activities, the leverage occasionally
    exceeds 10:1 for periods of time while still
    remaining well within what I have determined by my
    own experience and judgment to be acceptable
    limits. I am aware of how the foreign exchange
    market works and am accountable for my own trading.
    I do not need a regulation placed upon me that is
    arbitrary and has sought no coordination with my
    trading method. (Leaving the margin at
    100:1
    effectively stays out of the way.) To impose a 10:1
    limit on leverage is the equivalent of some random
    person coming in, entirely uninformed about the
    market and my method of engaging it, and meddling
    with stop losses on individual trades. Such
    intervention is not only unwelcome, it can impose
    significant losses on me because it seriously
    disturbs the balance of my trading. If I want to
    risk more than 10:1 leverage, that should be my
    prerogative.
    Reducing the leverage to 10:1 accomplishes nothing.
    It won [] t prevent novice traders from losing
    money; in fact, it will increase the odds of taking
    losses of some kind because the lower leverage
    increases the likelihood of a margin call. Even ifi0-001
    COMMENT
    CL-05356
    the losses are not catastrophic, they in effect
    paralyze the trader [] s ability to trade
    effectively. That may prompt some novices to put in
    more money and thereby lose more ~vhen, once again,
    what would now be the more frequent margin call
    asserts itself. This takes nearly all the
    flexibility out of retail trading by imposing the
    equivalent of an artificial and random stop loss.
    In other words, it is unprecedented and dangerous
    interference with my trading.
    In short, reducing the leverage to 10:1 hinders my
    ability to function as a trader. Moreover, the time
    and experience I [] ve devoted to developing my
    trading method may be rendered a vain effort as a
    result. And I imagine as well that such a
    limitation in leverage will hamper the freedom of
    all traders to develop a trading method based on
    their own experience.
    Rather than reducing leverage, perhaps the CFTC
    could publish guidelines for new retail traders to
    help provide realistic perspective to help them
    limit risk and maximize their trading efforts. It
    could become a trusted source of information, set
    apart from the noise of broker competition,
    explaining the relevant attributes of the forex
    market, market volatility, how leverage functions,
    and how to apply risk management.
    Thank you for your attention.
    Nate
    commenter name: Nate
    commenter withhold address on: ON
    commenter_city: Vista
    commenter state: Ca
    commenter zip: 92084
    commenter~ohone: 310-709-3260