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James Edlin Comment On Regulatory Notice 22-08

While it is a worthy objective to protect prospective investors from difficult to perceive or understand risks of investments having greater than usual complexity, the history of regulations limiting certain investment categories to investors of higher net worth or sophistication has largely served to deny the broader population access to higher potential returns that the favored might enjoy. Liberalizations such as Regulation Crowdfunding have proved a great success at broadening access to opportunities. New regulations going in the other direction seem like an inadvisable move backwards.

Edward Wetherell Comment On Regulatory Notice 22-08

To whom it may concern, The know your customer rule, regulation BI and and the pending IRA rollover rules are sufficient to regulate investment options, advice and documentation regarding investment options, recommendations and relationships between advisors and clients. Putting further restrictions and limitations on clients access to investment products will disproportionately and negatively impact smaller/average investors as compliance costs and time spent per transaction increase, these investors will have access to fewer advisor options.

Jed Bandes Comment On Regulatory Notice 22-08

I am outraged that you call Structured Product "complex investments." How can you paint these products with such a broad brush? Frequently companies use futures to hedge against many risks. Why not call their stocks complex investments as well? I believe simply informing clients of the risks, as our firm does with all the investments we sell, should suffice with any risk disclosure. We are not here to quiz clients and grade clients on their knowledge. Furthermore, we are not here to design tests and be graded on their efficacy.