Comment Text:
i0-001
COMMENT
CL-07004
From:
Sent:
To:
Cc:
Subject:
[email protected]
Friday, March 12, 2010 8:40 PM
secretary
[email protected]
'Regulation of Retail Forex'
RIN
3038-AC61
Mr. David Stawick, Secretary
Commodity Futures Trading Commission
1155 21st Street, N.W., Washington, DC 20581
Dear Sir:
The following is our opinion about new leverage, CFTC is proposing for off exchange Forex.
1] We agree that, the leverage must be controlled as far as limits are concern. But it should be left up to
a FCM / FDM to qualify, what leverage they need to give to its own customer. [ Brokerage firm is
allowed to qualify the customer for type of options they can trade, such as level 1 level 2 etc, on
security side ]. Also, as a fair practice, the risk must be then born by the FCMs, if they made such
decisions.
Under : Know your customer rule, have some questions inserted about the qualification on leverage
allocation and let FCM do some home work, on their own customers and CFTC should make them
responsible, if they made mistakes in evaluation and when some complaint come.
2] As far as business is concern, reducing the leverage will drive the revenues to overseas. Recently
many overseas companies have increased their business, as many US clients switch their accounts
overseas, where they can get 400:1 leverage.
News of reducing leverage from 100:1 to 10;1, has already started causing damages. For US economy,
this is little too early as far as timing is concern. Businesses are hurting and will do more due to this
action.
3] Many overseas Forex companies have started doing business in our own back yard and offering
400:1 leverage to US clients and US companies not allowed to offer more than 100;1 leverage. Imagine,
what will happen, when it is reduced to 10;1.
It does not make sense as this is going to hurt our own US Companies in worst stage of economy and
encourage outsiders to take advantage of US Customers. Unless outside companies are prohibited to
do Forex business with US Clients.
4] As NFA collects some cost per trade, this will effect their revenues too. It may not mean much, but
that money will be made by overseas authorities, as many people will go overseas due to more
flexibility in trading.
5] Some risk management education to trader will do a better job in long run. Have brokers required to
create some mandatory POP UPS on their platforms, when customer exceeds 50% margin used or
create alerts. Put some speed bumps, like exchange does. Mandatory education about risk due to high
leverage given to customers, before opening an account from broker may help in long run andi0-001
COMMENT
CL-07004
continuous education requirement about risk and leverage [ provided by brokers at no charge] from
FCM to their Forex customers will reduce many disasters. Higher capital requirement from customers
may
help.
6] More frauds will be done with US Customers and these high leverage intimidations from Foreign
companies will force innocents in to jurisdictions, where we have least control.
7] There are many small traders make a living trading Forex and heavily depend upon current leverage
of 100:1 Due to
lack of huge capital,
they will hurt their business due to this action.
We are registered with you and in our Forex trading practice, we use 50;1 in extreme case and once
exceeds 50:1 due to some un scheduled events news, we take scheduled partial loss, until, margin
used comes to 50:1 leverage or less. We do not have to take such loss in trading, but this practice have
kept us out of the issues of Margin call so far in our own trading. We can share with you our
knowledge and help the community.
For us, it may not effect much your decision either way due to our conservative trading, but we express
our opinion as a business point of view for entire community without our own selfishness. We want to
work with you and contribute our efforts in best interest of public.
Thank
you very much.
Peter
Dalai
Inventor and Developer of Magic Trader
TM
Inventor and CO Developer of FXTA [ A Thomson-Reuter's Product ]
SAVE DOLLAR ENTERPRISES, INC.
110-64 QUEENS BLVD, SUITE 244
FOREST HILLS, NY 11375
Member of NFA [352991]
Registered with CFTC
718-835-0793 [PHONE]
702-922-2470 [FAX]
SAVEDOLLA [email protected]
SKYPE ID: Peter Dalai
YAHOOID:
FalonDesai
WEB SITE: VVVVVV.MYFXTA.COM, VVVVVV.MAGICTRADERUNIVERSITY.COM
RISK
DISCLOSURE:
Trading Spot/OTC Foreign currencies/futures/options involves substantial risk
and there is always the potential for loss. Your trading results may vary. Because
the risk factor is high in Forex exchange/options/futures market trading, only
genuine "risk" funds should be used in such trading. If you do not have the extra
capital that you can afford to lose, you should not trade in the Futures /
options/Foreign exchange markets. You must be aware of the risks and be willing
to accept them in order to invest in the Future/options/ Forex markets. No
"safe" trading system has ever been devised, and no one can guarantee profits
or freedom from loss. Unique experiences and past performances do not
guarantee future results! Testimonials on MagicTraderUniversity.Com /
MyF×TA.Com websites are non-representative of all clients; certain accounts may
have worse performance than that indicated. Nothing in our live presentations,
training courses, website, or other materials shall be deemed a solicitation or an
offer to Buy/Sell currencies in Futures/options/Spot/OTC Forex Markets. No
representation is being made that any account will or is likely to achieve profits
or losses similar to those discussed or presented in any manner. Also, the past
performance of any trading methodology is not necessarily indicative of futures
results. Futures/options/ Foreign currencies trading involves high risks and you
can lose a lot of money.i0-001
COMMENT
CL-07004
HYPOTH ETICAL
DISCLAIMER
HYPOTHETICAL PERFORMANCE RESULTS HAVE MANY INHERENT
LIMITATIONS, SOME OF WHICH ARE DESCRIBED BELOW. NO
REPRESENTATION IS BEING MADE THAT ANY ACCOUNT WILL OR IS LIKELY
TO ACHIEVE PROFITS OR LOSSES SIMILAR TO THOSE SHOWN. IN FACT,
THERE ARE FREQUENTLY SHARP DIFFERENCES BETWEEN HYPOTHETICAL
PERFORMANCE RESULTS AND THE ACTUAL RESULTS SUBSEQUENTLY
ACHIEVED BY ANY PARTICULAR TRADING PROGRAM.
ONE OF THE LIMITATIONS OF HYPOTHETICAL PERFORMANCE RESULTS IS
THAT THEY ARE GENERALLY PREPARED WITH THE BENEFIT OF HINDSIGHT.
IN ADDITION, HYPOTHETICAL TRADING DOES NOT INVOLVE FINANCIAL
RISK, AND NO HYPOTHETICAL TRADING RECORD CAN COMPLETELY ACCOUNT
FOR THE IMPACT OF FINANCIAL RISK IN ACTUAL TRADING. FOR EXAMPLE,
THE ABILITY TO WITHSTAND LOSSES OR TO ADHERE TO A PARTICULAR
TRADING PROGRAM IN SPITE OF TRADING LOSSES ARE MATERIAL POINTS
WHICH CAN ALSO ADVERSELY AFFECT ACTUAL TRADING RESULTS. THERE
ARE NUMEROUS OTHER FACTORS RELATED TO THE MARKETS IN GENERAL OR
TO THE IMPLEMENTATION OF ANY SPECIFIC TRADING PROGRAM WHICH
CANNOT BE FULLY ACCOUNTED FOR IN THE PREPARATION OF HYPOTHETICAL
PERFORMANCE RESULTS AND ALL OF WHICH CAN ADVERSELY AFFECT
ACTUAL TRADING RESULTS.
REVISED: 1-22-10
Save Dollar
Enterprises,
Inc. Additional
Disclaimer
ANYTHING SHOWN OR DISCUSSED HERE OR WITHIN THE
MagicTraderUniversity.Com / MyF×TA.Com WEBSITE, MAGIC TRADER / F×TA
SUPPORT GROUPS, TRAINING MATERIAL, PROMOTIONAL MATERIAL OR ANY
RELATED SERVICES, OUR COURSES, PRODUCTS AND SERVICES, SHOULD BE
USED AS LEARNING AIDS ONLY AND SHOULD NOT BE USED TO INVEST REAL
MONEY. IF YOU DECIDE TO INVEST REAL MONEY, ALL TRADING DECISIONS
SHOULD BE YOUR OWN AND ARE SOLELY AT YOUR OWN RISK.
SAVE DOLLAR ENTERPRISES, INC MAY BE COMPENSATED FROM THE BID AND
ASK PRICES OF THE CURENCIES OR FROM COMMISSIONS COLLECTED AND
THE VALUES VARIES FROM FCM [BROKER] TO FCM [BROKER]
SAVE DOLLAR ENTERPRISES, INC. is a member of NFA (NO. 352991) and is
regulated by CFTC
Intellectual
Property
(IP) Rights
The principal of SAVE DOLLAR ENTERPRISES, INC. has intellectual property and
other rights related to the MAGIC TRADER(TM) / Forex Traders Advantage (FXTA)
products & trainings (patents pending). Any unauthorized use (including, but not
limited to: copying of ideas in part or full; duplicating any part of MAGIC TRADER
(TM) / F×TA Products, MAGIC TRADER® / FXTA training material; managing others'
money using MAGIC TRADER(TM) / F×TA; creating a signal service using MAGIC
TRADER ®/ FXTA in any manner; recording; creating MAGIC TRADER® / FXTA
educational classes, user groups, chat rooms, etc.; recording & distribution of
MAGIC TRADER® / FXTA charts; any commercial application, whether for profit or
not) will violate the intellectual property and other rights of the inventor, of SAVE
DOLLAR ENTERPRISES INC, and other parties. The violator will be responsible for all
legal fees, monetary damages and other penalties under U.S. and international law.
MAGIC TRADER(TM) / F×TA Products are only licensed for use on currency trading
and for Personal use only. Application of MAGIC TRADER(TM) / F×TA Products or
MAGIC TRADER® / FXTA services other than currencies including stocks, options or
any other Market vehicles, without a permission will be a Violation of our Intellectual
property rights. Ask Save Dollar Enterprises, Inc. for more details.
Patents (Pending) details: FXTA: Serial No. 11/523,368 & 12/189,761 ,i0-001
COMMENT
CL-07004
PCT/US2008/072830 [FINANCIAL DECISION SYSTEMS]
Magic Trader: Serial No. 61/210,599 [Multi Confirmation Risk Assessment & Trading
Systems]
Trade Mark: " Magic Trader" Serial no: 77- 698,213
Registered Service Mark Details : "Magic Trader" Reg. No: 3,692,439
Service Mark :"Magic Trader University" Logo Reg. No: 77-900,111
Service Mark :" "Scalp-Swing" Serial no: 77- 906,417
REVISED: 1-22-10
Options
Disclaimer
For the sake of simplicity, the examples that follow do not take into consideration
commissions and other transaction fees, tax considerations, or margin requirements,
which are factors that may significantly affect the economic consequences of a given
strategy. An investor should review transaction costs, margin requirements and tax
considerations with a broker and tax advisor before entering into any options strategy.
Options involve risk and are not suitable for everyone. Prior to buying or selling an
option, a person must receive a copy of CHARACTERISTICS AND RISKS OF
STANDARDIZED OPTIONS. Copies may be obtained from your broker, one of the
exchanges or The Options Clearing Corporation. A prospectus, which discusses the
role of The Options Clearing Corporation, is also available, without charge, upon
request at 1-888-OPTIONS. Any strategies discussed, including examples using actual
securities price data, are strictly for illustrative and educational purposes and are not
to be construed as an endorsement, recommendation or solicitation to buy or sell
securities.
The Dec 2009 Addendum to the Characteristics and Risks of Standardized Options
may be obtained from the Options Clearing Corporation
Rev. 1-09-10
Stocks/ ETFs/
ETNs/ ETCs/
Certain
Derivatives/
Indices/Bonds/
Mutual Funds
Disclaimer
Save Dollar Enterprises, Inc. is not a registered investment advisor with the
Securities and Exchange Commission [SEC] or with any state within the United
States. Save Dollar Enterprises, Inc. is not a registered broker/dealer with the
SEC or with any state within the United States. The information provided on
MagicTraderUniversity.com related to securities in the field of
Stocks/ETFs/ETNs/ETCs/Certain Derivatives/Indices/Bonds/Mutual
Funds/Options on those securities are for educational purposes only are not to
be construed as a recommendation or solicitation to buy or sell or hold
securities. Please consult your investment advisor for any recommendations.
Any analyses and/or risk evaluations provided on MagicTraderUniversity.com
is for educational purposes only and are not to be construed as a
recommendation or solicitation to buy or sell or hold securities.
Rev. 01-13-10
Equis
International/
Thomson Reuters
Disclaimer
Equis International/Thomson Reuters takes no responsibility to release
Magic Trader(TM) product in future or for any trading losses generated
by using Magic Trader(TM). Please do not contact Equis International /
Thomson Reuters sales department for any Magic Trader(TM) related
questions at this time. Equis International may charge for data feed &
use of MetaStock software in the future upon notice.
Rev. 01-13-10
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COMMENT
CL-07004
Save Dollar Enterprises, Inc.
Privacy Policy
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[see legal
section]
Additional
Disclaimers
Disclaimer: http ://myfxta.com/disclaimers.php
http://www.magictraderuniversity.com
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http ://www.optionsclearing.com/components/docs/risk stoc.pdf
http ://www.optionsclearing.com/components/docs/De
cember_2009_ODD_Definitive_Supplement.pdf
