During my active registration, I served as a branch, complex, regional, divisional and national Director.. Much of my experience related to the opening and supervision of option transactions. Since my retirement in 2004, I have maintained an active expert witness practice, primarily working from the Plaintiff or Claimant perspective. I have consulted on more than 700 arbitration or court cases (including state and federal criminal activity) and testified in excess of 100 times, very often related to options sales practice.

A SIMPLE SOLUTION I'm appreciative that FINRA and the SEC have considered the market implications of complex products and how they are offered to the investing community. There are certain products (i.e., leveraged and inverse ETF's) which investors should understand in more depth. That said, it is not appropriate for a third party to arbitrarily decide whether investors are capable of understanding the intricacies of a particular investment; by and large, investors are intelligent and certainly able to manage their own affairs.