Comment Text:
i0-001
COMMENT
CL-07176
From:
Sent:
To:
Cc:
Subject:
Mick Montgomery
Saturday, March 13, 2010 5:04 AM
secretary
[email protected]
Regulation of Retail Forex
RIN 3038-AC61
The CFTC proposed new rules are just going to drive MORE business away from the US into other countries and
some which will offer less protection, especially for the less knowledgeable and new traders. We have already
had financial firms that have moved their business out of the US due to the high liquidity requirements making it
uncompetitive to operate from the US, in tying up too much capital. We have moved accounts from US firms
where the FIFO rules meant that some of our strategies would not work because a slightly different time frame for
the trades closed out the wrong transactions.
Are you just trying to close down the US market to all the smaller investors and traders and only keep it for the
large ones? We know the risks and use appropriate limits and money management protection to reduce any
possible losses. It would make more sense to limit the size of any one trade to a percentage of the value of the
account. We have never placed a trade for more than 1 or 2 percent of the account. Maybe for some 5% or even
10% (in some cases) of the account is ok, but it would protect more if that was enforced.
If you would concentrate on the issues that caused the failures to happen in the first place, we will not be placed
in this situation again - Was it the forex market that caused this problem or the mortgage lending and packing up
of mortgages as secondary instruments to trade who's underlying value could not be relied upon.
There again, if you do continue with this rule, then it can only be good for the London market to keep its position,
as long as we get rid of that muppet Brown who is just as guilty as Clinton in relaxing the rules in the first place.
Mick Montgomery
Project Central Ltd
Tel: 020 8688 8002
