Subject: File No. S7-30-11
From: Bob Flowers
Affiliation: Law Student

July 17, 2011

Release No. 34-64874 File No. S7-30-11
RIN 3235-AL19
Retail Foreign Exchange Transactions

To whom this may concern,

Please accept these comments in light of recent developments surrounding The Dodd Frank Bill and Retail Foreign Exchange. First off I think that there is some serious misunderstanding and fear regarding the intentions of the commission in reviewing retail forex and metals trading.

I am one participant who started retail forex and metals in May of 2010 and I can tell you it has been one of the very best things (experiences) that has ever happended to me in my life.

There is something very challenging and special about this market that exists as one participates in this arena and in effect becomes transported front and center to all of the geopolitical events unfolding throughout the world. It is truly an incredible avenue to be able to participate in. It is a phenomenal educational and satisfying process one goes through in attaining competency that is hard to explain. I sincerely hope that this will never be jeopardized for retail traders in America. I believe the costs of discontinuing and or hampering retail forex and metals trading further would far outweigh the benefits. It would also be a tremendous blow to individual investors who have found this path to be very fullfilling and have worked very hard to achieve competency. I think that these instruments can operate successfully and with the integrity and standards the S.E.C strives to maintain in the interests of public policy. Please do not hamper forex and metals. I am very confident that a solution can be reached where the integrity of the business can be assured. Consider raising the education and captial requirements for firms wanting to operate retail forex and metals for further concerns about industry integrity. (For example require brokers to obtain their Series 7 and 66 licenses.) Could even require supervisors to obtain their CFP's in addition.

I remember my first forays into Forex and metals last year and my brokers warned me up front about all the begining pitfalls in trading forex... Warned me about trading during volatile news events. Told me how their price data feed was derived. Explained the mechanics behind the interbank market. Warned me about thin market hours. Had all sorts of webinars to make sure you could learn to operate the platforms and become as informed as you wanted to be. Gave you a free demo account to practice on all day and night if you had the time. Let you ask them technical and fundamental questions about valuations of price. Were careful to never to impart specific trading advice. Took your telephone calls for market questions during office hours. In essense an absolute professional and world class experience was provided to me. And, I never blew up an account

However, this is a difficult business to succeeed in as many fail. But, it can be done There are many individual investors that do develop the skills and talents to succeed as a retail forex trader. They may then go on and become some of the very best and brightest industry professionals reflecting a solid track record in a difficult market to succeed (but arguably the best and most satisfying) in an industry under review....

Please consider the individuals that have found this path to be a calling and vocation and the others that have worked very hard to ensure the most amount of integrity was maintained in forex and metals as any other reputable market.

Yours very truly,
Bob F