Comment Text:
i0-001
COMMENT
CL-07759
From:
Sent:
To:
Subject:
Lawrence Celin
Tuesday, March 16, 2010 1:09 AM
secretary
Regulation of Retail Forex
Gentlemen:
I'm sure that you have received lengthy comments about many aspects of this proposed rulemaking. I only wish to
add my support for two main points which I am sure others have made already more forcefully than I.
1) Additional rules that create a fair playing field and eliminate fraud are most welcome in the retail Forex
marketplace. Many of your proposals appear to be well thought out and likely to have their intended effect. I
support those parts of the proposal.
2) However, I believe that section 9 (a) is unlikely to be effective and will most likely have the opposite effect from
what was intended. The NFA has already implemented leverage requirements that are reasonable, and (albeit with
some grumbling) have been accepted. Traders can live with them. Reducing the leverage further to 10:1
maximum will, in my opinion case a flood of account relocations to the UK, Cyprus, Switzerland, or other domains
where people remain able to trade in a manner that they feel is essential to their success. As that happens, most,
or even all, Forex dealers operating under the U.S. rules will be forced to close due to lack of clients. That is what I
foresee happening, and what I share with you today. You will be left with no dealers to regulate, and I hardly think
that it is in the best interests of the bulk of traders to be forced offshore into other jurisdictions.
Just so that you may know I offer an impartial opinion for your benefit, I add that I am personally totally unaffected
by the proposed rules -- once the NFA decided that they knew better than I how to protect my trading profits, and
eliminated the possibility of hedging in theU.S, through their FIFO rule, my accounts departed theU.S, for an
offshore location where I am still able to hedge and protect profits.
In considering regulation, both present and future, I would recommend that the CFTC include specific consideration
of the fact that people will do what is necessary to preserve their economic freedoms, and to earn an income in the
manner that they believe best suits their own interests.
Both section 9 (a) and the NFA FIFO rule serve to eliminate basic freedoms to manage one's own assets, in my
opinion, and therefore can never be considered successful rulemaking. Saying that the CFTC "knows better than you
do what is good for you" is not a sufficent reason for eliminating our essential freedoms to decide and manage
ourselves.
Lawrence Celin
Batavia IL, 60510
greentrader@xoxy, net
