Comment Text:
i0-001
COMMENT
CL-08848
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Hardman, Harold
Monday, March 22, 2010 10:43 AM
secretary
Regulation of Retail Forex
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The Comment File
Harold L. Hardman
Comment on Proposed Retail Foreign Exchange Rules
March 19, 2010
On March 18, 2010, a meeting was held with FXSolutions in which they discussed their
concerns with the Commission's proposed rules regarding retail forex. In attendance from the
Commission were Dan Berkovitz, Harold Hardman, Vince McGonagle, William Penner, Sue
McDonough, and Duane Andresen. Michael Cairns, and Walter Zuck, FXSolutions, Scott Segal
and Susan Molinari, Bracewell & Giuliani, and Mark Ruddy, Ruddy Law Office, PLLC
represented FXSolutions. The major concern expressed with regard to the proposed rule was the
leverage requirement. In their words, the proposed leverage amount would cause them to lose a
number of customers, either forcing the demise of their business or pushing their business
offshore. From their prospective, there is not direct connection between the amount of leverage
and the goal to eliminate fraud in this market. They also noted that they have complied with the
NFA leverage amount of 100 to 1. They noted that they will be sending a formal written
comment for the rulemaking record along these lines.
