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Comment for Proposed Rule 75 FR 3281

  • From: Jim Stevens
    Organization(s):

    Comment No: 8388
    Date: 3/18/2010

    Comment Text:

    i0-001
    COMMENT
    CL-08388
    From:
    Sent:
    To:
    Subject:
    Jim Stevens
    Thursday, March 18, 2010 12:25 AM
    secretary
    Regulation of Retail Forex identification number RIN 3038-AC61
    To:
    David Stawick,
    Secretary, Commodity Futures Trading Commission,
    1155 21st Street, NW,
    Washington, DC 20581
    Regarding identification number RIN 3038-AC61 ... I don't believe I can
    say it
    any better than the text from the letter to me from one of my FCM's.
    Thus, I am expressing my voice to say DO NOT change the required leverage
    from what it is now, which ranges from 400:1 to 100:1 normally to the
    proposed
    10:1 leverage.
    Here is the text which gives just a few reasons why NOT:
    Should the 10 to 1 leverage rule proposed by the CFTC be adopted:
    ¯ Funded accounts currently in the U.S. system can be expected to go
    offshore.
    ¯ Forex fraud may worsen, not improve. Unregulated dealers from around
    the world will thrive, while operating
    without requirements for capital adequacy, risk management models,
    marketing ethics, dealing practices or
    even returning of customers funds.
    ¯ The United States may cost itself millions of dollars in trade revenue.
    ¯ Thousands of white collar jobs that require an advanced education and
    range from software developers to
    accountants to foreign exchange dealers may be eliminated, or move out
    of the United States.
    I have personally already moved 3 of my trading accounts out of the U.S.
    because of changes made
    to the rules governing trades with the FIFO rules put in place (not by
    your organization).
    I cannot believe (but may be wrong) that the goal is to push the rest of
    the US Retail Traders out
    of our country ... but if that's the case, the changes proposed by the
    CFTC on the leverage will
    clearly do the trick.
    My understanding is when the CFTC was established, one of the mandates
    was to enact no rules
    which would make our US Brokers less competitive. THIS WILL DO THAT and
    break that mandate.
    Again, my vote and I'm sure all the votes, or statistically "all" have
    been to say "No!"
    Thanks for your time and attention ... and appropriate action.
    Jim Stevensi0-001
    COMMENT
    CL-08388