Comment Text:
i0-001
COMMENT
CL-07328
From:
Sent:
To:
Cc:
Subject:
Peter J. Howard
Saturday, March 13, 2010 1:07 PM
secretary
[email protected]
Regulation of Retail Forex
Attn.
David Stawick, Secretary
CFTC (Commodities Futures Trading Commission)
1155 21
st
.
Street, N.W., Washington, DC 20581
USA
Re: RIN 3038-AC61
Dear David Stawick,
We and all our associates are
completely against
the proposed legislation that would impose a
reduction in leveraging on our FX trading in the USA. Does the CFTC even know anymore what the
retail market is for FX trading and how it is defined and what it entails? The retail
customer/investor is not comprised only of retired online hobby traders/gamblers, and it is not the
likes of many customers of, for example, the commercialized, mainstream "Forex.com" borderline
shady universe and similar TV commercials. The retail market INDEED consists of professional
traders using/depending on sophisticated systems and software, all who contribute to our economy
and who make a living from FX trading. These "retail" traders often have customers/investors of
their own managing millions of USD. By our industry norm, retail FX are accounts being up to ca.
USD 20 Million each, institutional trading/clients being over and above USD 20 Million. If retail
customers could be restricted to use only 10:1 leverage, this means that institutional trading floors
at our banks and financial institutions re: Wall Street (the ones who completely failed Americans
already once before) would still be allowed to use 100:1 leverage in their back office using client
deposited money, often and primarily for their own gains?!
No sound economist is his right mind and with any real world experience or any international
exposure would even consider such a proposal, never mind any individual who has any REAL idea
of how FX systems and EAs and HFT operate, systems that already execute stringent internal risk
management techniques using the industry standard of 100:1. The new regulation would also
mean that all presently successful systems and EA software/strategies would have to be completely
re-programmed/re-written thus increasing developmental costs in addition to the potential of
reducing FX trading activities tenfold, which is in affect what would happen.
Is your ailing/crumbling USD and disastrous/embarrassing American economy at this time not
evidence enough that more socialist impositions do not work in a free market society whether we
like it or not? I ask myself, what will it take then? Is it children with AADD or rebellious teenagers
who are running your country at this time?
In our day and age, it is a matter of a few clicks to move our FX operations
and funds
to platforms
outside of CFTC jurisdiction and this is EXACTLY what will result if the proposed new regulation is
imposed on North American traders. We all know the FX market is ca. USD 3 Trillion large on any
given day; the substantial profits made in this market on a retail level in North America will simply
dissipate in a matter of months and would then be enjoyed in/by countries like Malta, Switzerland
and other more suitable zones.
This new regulation if imposed would take away our/my livelihood in North America and will it
destroy the careers of many other astute and hard working North American day traders andi0-001
COMMENT
CL-07328
software developers as well, not to mention all the staff at brokerage houses across the country
who would in time also be laid off tenfold!
Personally, at my age and in my circumstance, there would literally be no point in me
living/working in North America anymore unless I want to flip burgers at your infamous McDonald's
restaurants or stock shelves at your beautiful WaI-Mart stores for the rest of my life making
minimum wage! If this regulation is actually passed, we will indeed and literally take all our money,
our trading, and our company outside the socialist grips of whatever the hell is going in the USA
right now.
Sincerely, a proud Canadian and FX trader/fund manager.
Peter J. Howard
Principal
CA.PJ~.['AL
Jericho Capital
220-318 Lorry Greenberg Drive
Ottawa, ON, K1T 2R5
Canada
Tel +1 (613)731.5557
Cell +1 (613)286.6553
Fax +1 (815)461.7810
Email: [email protected]
Skype: jerichocapital
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