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Comment for Proposed Rule 75 FR 3281

  • From: Matthew Moots
    Organization(s):

    Comment No: 6804
    Date: 3/11/2010

    Comment Text:

    i0-001
    COMMENT
    CL-06804
    From:
    Sent:
    To:
    Subject:
    Matthew Moots
    Thursday, March 11, 2010 11:30 PM
    secretary
    CFTC new leverage
    Dear Sirs,
    I would like to hereby express my deep concern with the intentions of CFTC to limit the maximal leverage for retail
    Forex brokers from the current 1:100 to 1:10. In my opinion, the following scenario is likely in that event:
    1. The maximal leverage reguirement will be increased for all US-regulated brokers from the current 1:100 to 1: 10.
    This will clearly demonstrate a complete dismissal of a regular Forex trader's interests if they happen to be
    conflicting with the interests of the "big wallets" - banks and non-retail futures brokers. We do not wish to be
    "protected" till we go broke just to make them even richer.
    2. US-based retail Forex brokers will sure be unwilling to lose their business completely. They've already got burned
    with the recent self-imposed regulations of the NFA (which is not even a government agency, although many traders
    are made to believe it is) and now clearly realize the 1:10 leverage will be the last nail into their coffin. These retail
    brokers will therefore start moving their businesses to other countries and servicing US customers from there,
    successful examples of which already exist: Dukascopy in Switzerland (which has recently introduced MT4 in addition
    to their custom platform), ATCBrokers and FXCM in the UK, FXDD in Malta, FXPro in Cyprus etc.
    3. The US government in response will do everything possible to prevent US traders from enjoying the benefits of
    being serviced in other countries by making overseas transactions to personal bank accounts even more controlled
    and restricted.
    4. Those traders who make a living from their trading will then have no other choice but to set up offshore
    companies for themselves through the Internet (contrary to a popular belief, this doesn't cost much - one can get
    an offshore company with an overseas bank account for as low as $1,500).
    5. As all (or most) trading accounts will be on the companies' names, the US government may heavily lose on the
    income tax they collect from US Forex traders. Thus, trying to harm the average Joe trader and make the banks and
    futures brokers richer at his expense, the government is harming themselves in the end.
    Since recently, America (which I really love) has been turning from a land of opportunities to a land of restrictions.
    Very sad to see this, indeed.
    Yours sincerely,
    Matthew