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Comment for Proposed Rule 75 FR 3281

  • From: Chris Capre
    Organization(s):
    Second Skies LLC

    Comment No: 7484
    Date: 3/14/2010

    Comment Text:

    i0-001
    COMMENT
    CL-07484
    From:
    Sent:
    To:
    Cc:
    Subject:
    [email protected]
    Sunday, March 14, 2010 2:08 PM
    secretary
    cftcfeedback@fxdd, com
    Regulation of Retail Forex - RIN 3038-AC61.
    Dear CFTC,
    In review of the proposal to change the leverage requirements to 10:1 in the Forex market
    (RIN 3038-AC61), I have the following response:
    Leverage has never been the deciding factor to make trading the forex market more or less
    challenging for the retail trader, investor, speculator, etc.
    There are other markets (for example) the Futures market where several instruments have higher
    leverage, such as 20:1 than the proposed 10:1. Regardless, the statistics for how many people are
    profitable in the futures market in comparison to the forex market are virtually the same so leverage
    logically cannot be the issue.
    By changing the leverage, you are not empowering people to make different decisions about risk-
    management.
    What does change things for speculators is education. By educating people how to use leverage and
    avoid over-exposure to any one instrument, you empower them to make more intelligent decisions.
    It has been said that leverage isa double-edge sword. The logic of any double-edge sword is
    learning how to use it properly, not in changing the edge or the blade.
    Logically, if you change the leverage for the Forex market, then you should change it for all markets
    regulated by the CFTC to a maximum of 10:1 as you are claiming this is the maximum leverage
    people can trade without over-exposing themselves. If you are claiming this is only applicable to the
    Forex market, then you should provide data to support such a claim.
    It should also be said if the CFTC is proposing to change the leverage requirements, it should clearly
    state on its site the primary reasons and arguments for such a change. If there are any data or
    statistics to support those claims, then they should be clearly noted as part of the theoretical reasons
    for proposing the change. This will allow speculators to makea proper decision and develop possible
    counter-arguments so the situation can be clearly investigated by both parties involved.
    Thus, I do not support in any way whatsoever the proposed regulations in changing the leverage to
    10:1.
    Kind Regards,
    Chris Capre
    Founder
    Second Skies LLC
    http ://2 nd SkiesForex.com
    Fund Manager
    White Knight Investments
    http ://www.whiteknig htfxi.com