Grant Lincoln Comment On Regulatory Notice 22-08
Complex products (ex: leveraged ETFs) are already limited in several wise ways. Limiting the leverage available to 3x is a good policy. However, completely gatekeeping who can access these products would simply increase inequality and unnecessarily increase costs for consumers. Gatekeeping access to all these complex opportunities would be akin to providing the unearned rent seeking through regulation that tax preparers enjoy now. To reduce inequality and increase prosperity for consumers, we need less unnecessary certification requirements, not less.