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Comment for Proposed Rule 75 FR 3281

  • From: Timothy Price
    Organization(s):

    Comment No: 6757
    Date: 3/11/2010

    Comment Text:

    io-ooi
    COMMENT
    CL-06757
    ~rol~l:
    Sent:
    To:
    Subject:
    Attach:
    [email protected]
    Thursday, March 11, 2010 12:49 AM
    secretary
    Public Submission for 2010-00456
    Public Submission for 2010-00456.zip
    Please refer to the attached file.Please Do Not Reply This Email.
    Public Comments on Regulation of Off-Exchange Retail Foreign Exchange Transactions and
    Intermediaries:
    Title: Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries
    FR Document Number: 2010-00456
    Legacy Document ID:
    RIN: null
    Publish Date: Wed Jan 20 00:00:00 EST 2010
    Submitter Info:
    first_name Timothy
    last name Price
    address1 332 Newberry Street
    city Grand Prairie
    country United States
    us state TX
    zip 75052
    company
    Gentlemen,
    I am writing to comment on the proposal to restrict leverage in Forex trading to 10 to 1
    leverage contained in these proposed rules.
    I speak as someone who trades the Forex for a living, as a private investor.
    The effect of the proposed rule would be to destroy the US market for small traders like
    myself and to drive my trading to foreign brokers who do not impose such a restriction on
    leverage.
    It would do so by creating an unacceptable risk reward ratio and make the cost of trading
    prohibitive to me and others like me.
    In addition, many investors would be forced to use foreign brokers who are not subject to the
    reserve funds requirements of US brokers & the risk of brokerage failure or even
    unscrupulous behaviour by foreign brokers will be far higher.
    The forex market is inherently less risky than other equities markets as one cannot risk more
    than the capital contained in ones trading account. There is no such thing as a "margin call"
    in Forex. My broker will automatically exit my positions on my behalf if my capital falls below a
    certain amount & I cannot owe any more than the amount in my account.
    I have traded Stocks, Options, and Commodities and I can state from hard experience that
    even with a maximum leverage of 2:1 (using margin) it is possible to lose far more than the
    balance of one's trading account.
    Forex is a fundamentally different market than Stocks, Options, or Commodities and should
    not be subject to the leverage requirements of those other markets.
    I urge that the proposed rules do not implement a 10 to 1 leverage requirement for Forex
    trading.