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Comment for Proposed Rule 75 FR 3281

  • From: Barry Chin
    Organization(s):

    Comment No: 8426
    Date: 3/18/2010

    Comment Text:

    i0-001
    COMMENT
    CL-08426
    From:
    Sent:
    To:
    Subject:
    Barry Chin
    Thursday, March 18, 2010 5:58 AM
    secretary
    Regulation of Retail Forex
    To: David Stawick:
    Re: Regulation of Retail Forex RIN 3038-AC61
    Mr. Stawick:
    I am sending this email to express my concerns about the proposed changes to Forex regulations, in particular, the
    proposed change in leverage. The rationale stated by FINRA for this change is based on the assumption that traders do
    not use leverage properly. The FINRA proposal fails to recognize that leverage merely allows a trade to exercise more
    precise risk management in relation to the size of their positions. Having leveraging capabilities allows a trader to adjust
    the size of their stop dynamically, while still maintaining a fixed position risk. Moreover, not having adequate leverage
    available will punish the traders who are already exercising appropriate risk management. Leverage reduction would
    actually increase the risk of a margin call when risking the same amount in both scenarios. The bottom line is that the
    expected end result would be US based traders investing their money with overseas brokers.
    Thank you for your attention.
    Barry Chin
    398 S. Roosevelt Ave
    Pasadena CA 91107