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Comment for Proposed Rule 75 FR 3281

  • From: Mikhail Kostin
    Organization(s):

    Comment No: 8913
    Date: 3/22/2010

    Comment Text:

    i0-001
    COMMENT
    CL-08913
    From:
    Sent:
    To:
    Cc:
    Subject:
    Mikhail Kostin
    Monday, March 22, 2010 9:03 PM
    secretary

    [email protected]
    Regulation of Retail Forex
    RIN 3038-AC61
    This is my argument why reducing the leverage down to 10:1 is a disastrous idea.
    If my F OREX broker decides to leave the business (bankruptcy or
    whatever) I will have a little chance to recover my account, because
    the FOREX market is not regulated. To mitigate possible losses I would
    keep 2/3 of my trading account in a bank and only 1/3 is kept in the
    brokerage account. Position sizes are chosen as if all 100% of the
    account is available for trading. The 10:1 leverage will be too low to
    use this strategy, so traders would have to keep all the capital in
    the brokerage accounts which in turn means they can loose everything
    due to broker failure. If trading account is really big or other
    people's money used (moral responsibility) then only 10% of the
    trading account is kept with the broker. This is only possible with
    100:1 leverage.
    To summarize, if you want to reduce the leverage, make FOREX regulated
    first. Or better yet do not touch anything. Almost any interference
    from the government turns into a disaster. I know better how to run my
    business.
    Mikhail Kostin, Ph.D.