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Comment for Proposed Rule 75 FR 3281

  • From: Josua Carrera
    Organization(s):

    Comment No: 6602
    Date: 3/8/2010

    Comment Text:

    i0-001
    COIMMENT
    CL-06602
    From:
    Sent:
    To:
    Subject:
    josua carrera < bluesession@ hotmail.com >
    Monday, March 8, 2010 7:32 PM
    secretary < secretary@ C FTC. g ov >
    RE: CFTC Propsal - 3 weeks left for comments
    From: AIpa ri_U S_LLC@ ma il.vresp.com
    To: bluesession @hotmail.com
    Subject: CFTC Propsal - 3 weeks left for comments
    Date: Mon, 8 Mar 2010 20:33:50 +0000
    Deberia ser libre y el menor intervencionismo posible para que la ecomia sea mas
    din~mica.Adem~s estas normas no protegen al inversor, cualquiera que invierta en forex sabe los
    riesgos y est~ sobre aviso de ello.
    Dear Traders,
    We are sending you this follow up email to remind you that you have a
    voice and there are only three weeks left! The CFTC is accepting
    comments on it's proposal until March 22, 2010. We strongly encourage
    you to submit your comments to them during this time period. Below you
    can find the response of Alpari (US) in regards to the new CFTC proposed
    regulations.
    Alpari (US) Speaks out about the CFTC
    Proposal
    New CFTC Proposed Rule
    On January 13, 2010, The Commodity Futures Trading
    Commission (CFTC) released a public proposal,
    Regulation of
    Off-Exchange Retail Foreign Exchange Transactions and
    Intermediaries,
    which imposes new requirements on the
    U.S. Forex industry. The proposal significantly changes thei0-001
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    leverage permitted on certain accounts and, if passed, would
    have a drastic effect on retail investors, In the CFTC
    proposed regulation, leverage in retail forex customer
    accounts would be subject to a 10-to-1 limitation,
    Currently, the CFTC enforces 100:1 leverage (a 1% margin
    requirement) to open and maintain a position on a forex
    transaction, With the 10:1 leverage proposed, retail traders
    would be subject to a 10% margin requirement, Retail
    traders would have to invest significantly more to place
    trades of the same size, ultimately resulting in a decreased
    return or loss on invested margin,* The risk-reward ratio
    that is so appealing to the average investor today under
    100:1 leverage would no longer be available if the proposal
    is passed,
    The effect of this change can be summarized through the
    following example:
    Currency
    Price
    Transaction
    Current Margin
    Proposed Margin
    Pair
    Quote
    Size
    Requirement at Requirement at
    100:1 Leverage 10:1 Leverage
    EUR/USD
    1,4285
    1 standard lot $1,428,50
    $14,285,00
    = 100,000
    GBP/USD
    1.6370
    1 standard lot $1,637.00
    $16,370.00
    = 100,000
    Where we stand
    Alpari (US) has always been a strong supporter of ethical
    and fair business practices and the protections offered to
    traders through industry regulation. However, AIpari (US)
    does not support
    this
    CFTC proposal.
    Alpari (US) believes that this proposal discourages
    beginners from developing and strengthening their tradingi0-001
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    style. It effectively prevents investors from evaluating their
    own appetite for risk and making personal investing
    decisions.
    We place a strong emphasis on educating traders to make
    informed and responsible decisions. We believe that, with
    proper education, it is not necessary for the U.S. Forex
    industry to be subject to these regulations. Only recently
    have the doors opened for retail investors to trade in this
    market; these doors are effectively closed through the
    proposed rules, once again making the FX market accessible
    only to financial institutions.
    You have a voice
    Our goal is to guide you in understanding the intentions and
    ramifications of this proposal and remind you that, as a
    retail investor, you have a say in how your freedoms are
    controlled. We believe that this is a decision to be made by
    the traders, not the regulators. You are the largest group
    who can make these ramifications heard.
    We encourage you to send your comments to the CFTC
    during the 60 day period, ending on March 22, 2010. If you
    have an opinion on whether the CFTC should restrict
    leverage across the board to 10 to 1, we want you to voice
    it. Send your comments to
    [email protected]
    and include
    "Regulation of Retail Forex" as the subject line of the
    message. Additionally, you can file comments
    online, by fax
    at 202-418-5521 or by mail to:
    Secretary of the Commission
    Commodity Futures Trading Commission
    Three Lafayette Centre
    1155 21st Street NW
    Washington, DC 20581i0-001
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    Team of Alpari (US)
    14 Wall Street Suite 5H
    New York, NY 10005
    Tel: 646.825.5760
    Fax: 646.825.5761
    www.alpari-us.com
    NFA ID: 0379678
    *The potential of profit is equal to the risk of loss on all
    leveraged transactions.
    Risk Warning: Trading foreign exchange, commodity futures,
    options, precious metals and other over-the-counter
    products carries a high level of risk and may not be suitable
    for all investors. The high degree of leverage associated
    with such trading can result in substantial losses, as well as
    gains. The past performance of any trading strategy or
    methodology is not indicative of future results, which can
    vary due to market volatility; it should not be interpreted as
    a forecast of future performance. You should carefully
    consider whether such trading is suitable for you in light of
    your financial condition, level of experience and appetite for
    risk, and seek advice from an independent financial advisor,
    if you have any doubts. AIpari (US), LLC is registered with
    the CFTC as a Futures Commission Merchant and is a
    member of the NFA
    - Member ID: 0379678.
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    whether stored on a computer or otherwise.i0-001
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    Phone:
    1-646-825-5760
    Email: [email protected]
    Web: www.alpari-us.com
    14 Wall St., Suite 5H, New York, NY 10005
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