Comment Text:
i0-001
COMMENT
CL-06449
From:
Sent:
To:
Subject:
kevin koch
Sunday, March 7, 2010 2:55 AM
secretary
Regulation of Retail Forex -- Concerns
Dear Secretary Stawick,
I would like to express some concern about modifications to the leverage ruling on OTC currency contracts. One of
my brokers gave me the following number to quote: RIN-3038-AC61. I currently trade currencies and futures but
use to be a commodities / currency hedge fund risk manager.
I am aware of the risks. I can understand the CFTC's concern for retail clients with 100 times leverage and I would
never run with this much leverage. However, 10 times leverage bringing it to the same as futures would not make
sense for me to continue trading these. As a risk manager, I learned a lot about counterparty risk and those risks
are much greater with OTC than with required futures clearing. This ruling would move me to close my retail FX
account and trade my currencies on the futures exchange. If the purpose is to stop all OTC retail trading than this
is a good course of action; otherwise moving the leverage to say 20 times max may be more reasonable.
Sincerely,
Kevin D. Koch
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