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Comment for Proposed Rule 75 FR 3281

  • From: Kelly Goode
    Organization(s):

    Comment No: 8053
    Date: 3/16/2010

    Comment Text:

    i0-001
    COMMENT
    CL-08053
    From:
    Sent:
    To:
    Subject:
    Kelly Goode
    Tuesday, March 16, 2010 9:07 PM
    secretary
    Regulation of Retail Forex
    To Whom It May Concern:
    These comments are being written and offered in response to RIN 3038-AC61, Regulation of Retail
    Forex.
    As a current independent retail forex trader, these regulations stand to greatly impact me and my ability
    to earn a living. It is the obvious intent of the CTFC to provide consumer protection; however, this is a
    delicate balance and if not structured adequately will lead to consumer neglect.
    For the most part, I applaud the CTFC for many of the proposed regulations. In particular, the strict
    enforcement and regulation of forex brokers via dealing desk requirements, identifying and prosecuting
    scams and fraudulent companies who mislead and manipulate unsuspecting persons, disclosure and
    record keeping stipulations and establishing financial requirements to ensure fiscal stability should all be
    implemented as soon as possible.
    My most serious issue is concerning the proposed margin change requirement. As someone who earns
    their living by forex trading, mandating margins to be no more than 10:1 would be devastating and put
    me out of business. In order to continue I would be forced to take my business and accounts to a foreign
    company which saddens me greatly. I am a 'buy USA' kind of gal and being pushed by my own
    government over-seas is just mind-boggling.
    And, frankly, it is insulting that federal regulations state you are acting to protect individuals who are
    'uneducated'. I have devoted countless hours over several years to learn both how to trade and how to
    manage the financial risk associated with trading. Please do not make a sweeping disparaging remark
    and continue to believe that we, who trade retail forex, are an uneducated group.
    There will always be certain financial risks in life: gambling, stocks, forex, futures trading (has a higher
    margin than 10:1) and recently the national housing market was more of a risk than my forex trading. It
    is how we all manage our risk that matters.
    Please consider amending your regulations to meet the recent margin changes implemented last summer
    by the National Futures Association (NFA) of 100:1. This will provide reasonable stability for traders,
    protect jobs of American forex brokers, and allow those of trade for a living to stay in business.
    This is a freedom of choice issue --
    please keep the 100:1 margin requirements now is existence.
    Thank you for your consideration.
    Kelly Goode
    Alaska