From: Brad Georges
Sent: Wednesday, December 19, 2012 5:30 PM
To: Rutkowski, Joanne; Gauch, Bonnie L.
Cc: Murphy, Elizabeth
Subject: RE: Rule 15b-12;

Dear Joanne, Bonnie and Leila

On Betsy Murphy’s suggestion I am reaching out to you regarding Rule 15b-12. Primarily I would like to plead with the SEC to preserve its current position of oversight for Broker Dealers offering foreign exchange (FX) trading and hedging to their clients, including retail.

Following are a few points to discuss:

In conclusion FX is just another asset class like stocks, bonds and money market deposits.  If brokers offer margined accounts as they do in stocks, there is no difference. And brokers are not going to offer margin levels that cannot be supported by their risk management systems nor their customer suitability standards, just as they would not offer options or leveraged stock trading to their clients in an unsuitable manner.

In my opinion the most compelling reason to keep FX within your oversight is to help your Broker Dealers keep their clients in their own stables before clients bolt for the specialist online trading/gaming types of operations that are taking market share rapidly from the online stock broking industry across the globe.  Let’s help the big blue chip firms serving the larger retail client base to keep their clients in an environment where they offer the full suite of prudential investment products for a well balanced portfolio that is less likely to be over traded.

Would it be possible to arrange a telephone call with one of you one afternoon? (I currently reside in Melbourne Australia where the time is 8 hours earlier.)

Kind regards

Brad Georges
Managing Director