Skip to main content

Richard M Primavera Comment On Regulatory Notice 24-13

RICHARD M PRIMAVERA
JEFFERIES LLC

I believe there are investors who can realize profits from this trading model.

That said I have thought about simplifying the rules concerning any day trading.

I believe these investors should have skin in the game and as such must maintain a minimum equity of $100,000. in their margin account at all times.

And in the absence of time and tick evidence, I would cap the gross commitment on a given trading day to be no more than 3 times their equity.

The difference of any day trading gross greater than 3 times the margin account equity is a margin call.