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Comment for Proposed Rule 75 FR 3281

  • From: Joshua Glazebrook
    Organization(s):

    Comment No: 932
    Date: 1/20/2010

    Comment Text:

    i0-001
    COMMENT
    CL-00932
    From:
    Sent:
    To:
    Subject:
    Joshua Glazebrook
    Wednesday, January 20, 2010 8:28 AM
    secretary
    Regulation of Retail Forex
    RIN3038-AC61
    To Who It May Concern,
    Information has been going around that the CFTC are going to introduce a leverage limitation of
    "10:1", on every currency pair including the most highly traded pair like the EURUSD,
    USDJPY, GBPUSD, AUDUSD, USDCHF, USDCAD, EURJPY or GBPJPY.
    To put it bluntly the people who proposed this idea within the CFTC are flipping nuts. All you are
    going to do is close down legitimate USA based forex businesses and limit the abilitieis of both trader
    and retail forex broker alike. I believe an internal investigation to see whether any CFTC proposer of
    this 10:1 leverage limitation has any vested interest in off shore forex broker businesses, because it is
    obvious to me that these are the people who stand to benefit by such an excessive, extreme ruling.
    If you want to stop illegitimate forex dealers from doing illegitimate stuff, have a tick analysis rule to
    prevent fake slippage / gappage in the bid / ask quotes. Or you could have no requote rule allowed in
    the retail forex market as they are not trading in the complete market but a sand box market where
    slippage/gappage is a made up scenario.
    Maybe if your aiming to protect the new trader, the new trader must take a test that demonstrates that
    they understand the effects of leverage. Don't screw up an entire industry because there are a few
    stupid people that don't understand the risk they are entering into.
    There are many brokers around the world now offering more than 100:1 and traders will very quickly
    pull all there money out of the USA brokers and migrate to international brokers if a 10:1 leverage
    limitation or even a 50:1 leverage limitation is introduced.
    As a customer of a retail market broker I enjoy high leverage (200:1), as I have a high tolerance to
    risk and understand the negatives. However, the high leverage and the significant trends found in the
    forex market makes it possible for every person to make a living out of trading and not just the big
    financial institutions.
    A 10:1 leverage limitation on major pairs or even the larger crosses, is just plain stupid. A 50:1
    leverage limitation isn't good enough for most traders.
    Major USD pairs in my opinion include EURUSD, USDJPY, GBPUSD, AUDUSD, USDCHF
    and USDCAD.
    Significant crosses include: EURJPY, GBPJPY, AUDJPY, CHFJPY, EURGBP, EURCHF, GBPCHF,
    EURAUD and GBPAUD.
    Yours sincerely
    Joshua Glazebrook
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