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Comment for Proposed Rule 75 FR 3281

  • From: Michael C Baron-Jeffrey
    Organization(s):

    Comment No: 6012
    Date: 3/4/2010

    Comment Text:

    i0-001
    COMMENT
    CL-06012
    From:
    Sent:
    To:
    Subject:
    Michael
    Thursday, March 4, 2010 1:25 PM
    secretary
    Regulation of Retail Forex
    While I have compassion for people who loose large portions of their resources to
    investments, it is imprudent to penalize the vast majority who don't, along with
    the rest of the citizens of the United States.
    Late last year, I received notice that maximum leverage was reduced by 50%,
    from 200:1 to 100: 1. While disappointing, the concept was tolerable. Reducing the
    leverage further, is not only unfair, it appears imprudent, as doing so not only
    limits the profitability for most retail investors, it reduces the corresponding tax
    base.
    Taxes collected from Forex trading are as high, if not higher than personal income
    tax. Whereas those who suffer loses may be able to recover a portion of their
    losses through taxes in further years, reducing the profitability of the rest of us,
    reduces Federal revenue that supports the quality of life of all US citizens. For this
    reason, reducing profitability of individuals who invest in forex trading impacts all
    citizens, rather than the few that the change in regulation would protect.
    Furthermore, the protection sought is protection from self. Many financial advisers
    recommend allocating no more than 5% of assets to speculative investments.
    People who invest more are placing their self and their household at greater risk of
    loss. While their individual loss is disappointing, their personal loss does not
    warrant taking measures that amount to an exponentially larger loss to the
    balance of individuals, in the United States and abroad, who benefit from the tax
    base of the United States.
    Further reduction of the investment ratio in forex retail accounts communicates a
    counterproductive message. The message is investors
    do not have to accept responsibility for their actions.
    do not have to research the risks and rewards of investing.
    do not have to monitor their investments.
    They can escape full responsibility for their actions, including the portion of their
    assets that they devote to speculative investments, by coercing our government to
    restrict everyone else.
    Forex trading is one of the purest forms of capitalism available. Our country was
    built upon the principle of "life, liberty and pursuit of happiness" for everyone, not
    just the rich or otherwise privileged. The retail forex market provides access to
    individuals other than the wealthy. It positions anyone willing to learn about
    investments, capitalism, and human behavior a reasonable opportunity to acquire
    wealth. Reducing the ratio further substantially limits that ability.i0-001
    COMMENT
    CL-06012
    Finally, other alternatives are available, for example:
    Increase public awareness of risks through advertising and other campaigns
    Require forex trading firms to utilize risk reduction technology that limits
    loss to the amount the investor deposits with the firm. Doing so optimizes
    return, limits loss, and supports individual responsibility.
    I am disappointed with the regulation that reduces ratios from 200:1 to 100: 1.
    Reducing them further is appealing. Doing so encourages irresponsibility rather
    than personal responsibility; it not only reduces the profitability of most investors,
    it also reduces much needed Federal revenue; and finally, it removes one of the
    few remaining economic opportunities available to most citizens of the United
    States.
    Regulation does not prevent individuals from doing foolish things. It does not
    foster personal responsibility. Furthermore, the proposed regulation will increase
    losses among millions of US citizens and people around the world by removing
    Federal revenue associated with successful forex investment.
    Sincerely,
    Michael Christian Baron-Jeffrey
    Further contact information available by request. Simply reply.