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Comment for Proposed Rule 75 FR 3281

  • From: Brian Crawford
    Organization(s):

    Comment No: 8162
    Date: 3/17/2010

    Comment Text:

    i0-001
    COMMENT
    CL-08162
    From:
    Sent:
    To:
    Subject:
    Attach:
    [email protected]
    Wednesday, March 17, 2010 10:43 AM
    secretary
    Public Submission for 2010-00456
    Public Submission for 2010-00456.zip
    Please refer to the attached file.Please Do Not Reply This Email.
    Public Comments on Regulation of Off-Exchange Retail Foreign Exchange Transactions and
    Intermediaries:
    Title: Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries
    FR Document Number: 2010-00456
    Legacy Document ID:
    RIN: null
    Publish Date: Wed Jan 20 00:00:00 EST 2010
    Submitter Info:
    first name
    last name
    address1
    city
    country
    us state
    zip 77
    company
    I favor the proposal that Forex Brokers be registered, regulated and maintain minimum capital
    levels.
    I favor limiting leverage extended by Brokers to retail customers at a level of 100:1 on major
    currency pairs and 25:1 on non-major currency pairs.
    I favor a requirement that retail customers maintain brokerage account balances in reserve
    equal to twice the amount the customer has at risk, meaning for example, if a customer buys
    a standard-lot EUR/USD contract (100,000) for $1,500 then the retail customer should have
    a minimum additional $3,000 in non-risk reserve funds on deposit with the Broker. In other
    words, to initiate (open) one contract of cost $1,500, a retail customer should have a
    minimum of $4,500 on deposit before purchase.
    I believe that retail customer deposit requirements should not in any case exceed 3-to-1,
    meaning require no more than $4,500 in not-at-risk deposit with the Broker for every $1,500
    at risk, i.e. $6000 account balance to open a $1,500 standard contract EUR/USD lot of
    100,000.
    Respectfully, Brian Crawford