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Nicholas Gault Comment On Regulatory Notice 22-08

I am in favor of allowing the public to continue its access to leveraged and inverse funds such as ProShares/ProFunds. These funds are effective vehicles for hedging my portfolio. I fully understand the risks and choose to use these funds because they offer a simple way to hedge or leverage without getting into more complex vehicles like options or taking on margin debt. In my opinion, it is much more risky to use margin debt and options to achieve similar strategies as those enabled by inverse and leveraged funds.

Vincent Butcher Comment On Regulatory Notice 22-08

I understand the risks involved in leveraged investments and I am fully capable of using such instruments in my portfolio to increase the diversity and return of my accounts. All investments carry risks and I have used leveraged funds for over ten years. I should not be required to take any tests or special processes as I feel comfortable and accomplished that my experience and portfolio demonstrate a clear understanding of all risks. Leveraged funds are an integral part of my portfolio that I rely on to increase my return.

Francis Coombs Comment On Regulatory Notice 22-08

I am writing to oppose the radical limitations on my investments proposed by the Financial Industry Regulatory Authority (FINRA). Under the long-standing disclosure-based system, investors have the right to decide which public equities, bonds, and funds they want to buy. The freedom to access a broad range of investment products help me build better portfolios and limit my risks in the market. FINRAs definition of complex products is so broad, arbitrary, and vague that it could invalidate persons from a vast number of commonly used public securities.