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Comment for Proposed Rule 75 FR 3281

  • From: Paul Towne
    Organization(s):
    Back Bay FX Services LLC

    Comment No: 97
    Date: 1/15/2010

    Comment Text:

    i0-001
    COMMENT
    CL-00097
    From:
    Sent:
    To:
    Subject:
    Paul Towne
    Friday, January 15, 2010 2:55 PM
    secretary
    Regarding: CFTC Release: 5772-10 - Date: January 13, 2010
    Regarding: CFTC Release: 5772-10 - Date: January 13, 2010
    Dear Sir/Madam:
    As a current small business owner who has been in a CFTC-regulated entity since 2005, I strongly urge you to
    consider not invoking the 10:1 leverage proposal included in the CRA proposal.
    I firmly believe that the proposed changes will not only devastate the retail Forex market but it will also
    eliminate small FX firms and affiliates that operate in the space. Our industry, as are many other industries, is
    fueled by innovation and competition. Without the innovation and competition provided by small firms, it
    potentially opens clients to the pressures associated with large firm consolidation.
    I understand that the FX industry needs restructuring and regulation, which I am in favor of, but deleveraging
    the US market to this magnitude seems like a 'margin call' for brokers and traders.
    Regards,
    Paul Towne
    NFA ID # 0373858
    Tel: 617.357.6100
    Fax: 617.357.5100
    Web: http://www.backbayfx.com
    E-Mail:
    paul.towne@ backbayfx.com
    Skype: Backbayfx
    Back Bay FX Services, LLC
    425 Boylston Street, 2nd Floor
    Boston, MA 02116