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Comment for Proposed Rule 75 FR 3281

  • From: Vincent K Skupeika
    Organization(s):

    Comment No: 8703
    Date: 3/20/2010

    Comment Text:

    i0-001
    COMMENT
    CL-08703
    From:
    Sent:
    To:
    Subject:
    Vincent K Skupeika
    Saturday, March 20, 2010 3:51 PM
    secretary
    Re: Regulation of Retail Forex - Against Curtailing Leverage to 10 percent
    David Stawick, Secretary
    Commodity Futures Trading Commission, Washington DC
    Re: ID number RIN 3038-AC61
    Dear Mr. Secretary:
    Please DO NOT Curtail Leverage to 10:1 on OTC Forex Firms.
    Curtailing leverage to 10:1 on OTC forex firms will result in a VIOLATATION OF YOUR MANDATE TO PROTECT
    THE RETAIL INVESTOR for the following reasons:
    -
    Retail investors will be forced to move to offshore unregulated dealers putting them at more risk.
    -
    Retail investors, if they stay with their current dealers, will be forced to keep much more capital at risk in their
    accounts, and be subjected to more risk as a result.
    - There has been no consultaion with the NFA, Providers, or advisory groups before deciding on the proposed
    margin changes by the CFTC.
    - This margin change would force the retail investor to adopt only the longest term trading strategies, and would
    effectively destroy any short term trading strategies. This would limit the choices available to the retail investor, and
    the long term trading strategies would force the retail investor to take on long term exposure to market risk.
    - The proposed margin change would cause a loss of jobs here, and move them overseas, with the increased
    probability of the retail investor being exposed to widespread fraud, in using unregulated overseas dealers, who
    would be the ones ultimately benefitting from this action.
    - The CFTC should not be attempting to fight fraud using leverage changes. For the reasons stated above, this will
    not benefit the retail investor.
    -
    It appears that only the overseas competitors are supportive of this action. Does that come as any surprise?
    - I ask that the CFTC not go through with these proposed margin changes. Honor your mandate to protect the retail
    investor.
    Thankyou.
    VK
    Skupeika Davie, FL