Patrick Marshall Comment On Regulatory Notice 22-08
Investors know the risks. They should be able to take them.
For the Public
FINRA Data provides non-commercial use of data, specifically the ability to save data views and create and manage a Bond Watchlist.
For Industry Professionals
Registered representatives can fulfill Continuing Education requirements, view their industry CRD record and perform other compliance tasks.
For Member Firms
Firm compliance professionals can access filings and requests, run reports and submit support tickets.
Investors know the risks. They should be able to take them.
I object to the proposed limitations on investing in "complex" leveraged or inverse funds.
When the market is down, these investments are needed to protect investments from loss of value.
Why restrict us from using these investments? A needless restriction of our rights to manage our affairs. Government overreach at its finest.
I consider investing my own money a decision that I am fully capable of making without additional controls. The changes being considered to gate who has access to leveraged and inverse ETFs/Funds are barriers to entry. Personally, I use them in my investing to better manage market downturns and to gain better returns. In 2020 when the market was getting hammered, I was able to invest in an inverse ETF which significantly protected my down side. More recently, I was able to invest in a leveraged ETF which brought me significant returns.
I oppose the possible rule changes to limit access to " complex products " such as leveraged ETFs.
User education is the way to go.
As long as investors are warned of the risks , the access must not be taken away from individual investors.
Leveraged ETFs are an important part of my investing strategy. Of course, each individual needs to understand how these investment vehicles are designed and meant to perform, the pros and cons for them in an investment strategy, and most importantly, the risks.
But just like we don't ban automobiles because they are dangerous, but instead install seatbelts and require a license to drive, a blanket banning of leveraged ETFs for the individual retail investor would be akin to taking away one's vehicle. Don't do that!
Limiting investments to the ultra-wealthy erodes trust in FINRA. All investors assume risk and the investors, after being made aware of the risks, should control their investing behaviors. Please do not limit my investment options just because Im not a member of the elite club.
Leverage is a fantastic wealth generator when used responsibly. You shouldnt take away my ability to use leveraged ETFs in a well balanced portfolio. Recommend additional education or waivers with these instruments, but dont take them away.
Please do not change my ability or freedom to buy inverse fund shares.
It is an important investment vehicle for my future security.
Thank you
Do not impose restrictions on my rights to invest in leveraged and inverse funds. These funds are very useful in protecting my investments and enhancing my returns and used only as a limited part of my overall investment. These tools should not be limited to be used only by the privileged. They should be available to small independent investors, like myself. I do not need these regulatory measures imposed on me. Everyone is aware that there are risks involved with any investment.
Investing in inverse index ETFs has been an integral part of my investment strategy for many years. I think the average investor can easily understand how they work and no additional restrictions are necessary to screen who is allowed to invest in them