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Comment for Proposed Rule 75 FR 3281

  • From: Ray Myers
    Organization(s):

    Comment No: 6270
    Date: 3/5/2010

    Comment Text:

    i0-001
    COMMENT
    CL-06270
    From:
    Sent:
    To:
    Subject:
    Ray Myers
    Friday, March 5, 2010 3:49 PM
    secretary
    'Regulation of Retail Forex'
    Mr. David Stawick,
    I would like to offer my opposition to the changing of leverage for retail Forex traders from 100:1 to
    10:1 per RIN 3038-AC61.
    Such a restriction would make it impossible for me to trade because the margin requirement would
    exceed my current financial ability. I have studied for over 2-years the trading of forex and have
    managed to maintain my account without losing everything during the learning curve. I am just now
    realizing some success and all the effort would be for naught if the leverage is changed.
    Losses from trading do not come from excess leverage but from improper risk control. I have
    experimented with several different forex trading platforms, and everyone has made available expert
    advise for novice traders. The one most common lesson is managing risk by not committing more than
    2% to 3% of an account on any one transaction. Using those parameters it would make no difference
    what the leverage is, your account would be safe from a catastrophic mistake. By changing the leverage
    you would actually force some traders into funding an account in an amount greater than they would be
    able to afford losing. By having higher leverage I am actually able to trade a meaningful amount on any
    one transaction without ever risking any more than whats in the trading account.
    Forex leverage for small retail traders is not the same as the leverage being used by the big market
    traders. In the case of Goldman Sachs for instance, they have all the resources of the bank plus the
    resources of the U.S. taxpayer at risk on every trade if they don't manage the risk. A retail forex trader
    never has more than the amount in the trading account at risk because the vendor automatically closes
    all open trades if the account goes below the leverage amount. Granted there can be a rare case that the
    price gaps past a stop, but even in those cases the vendor closes the account immediately.
    I can see no benefit from changing the leverage, but it would certainly restrict access to Forex to many
    people during a time in our country that opportunities are few and far between. Please leave the leverage
    at 100:1 or greater.
    Thank you;
    Ray Myers