Bryon Mangler Comment On Regulatory Notice 22-08
I would be categorized as a "retail" trader. The assumptions being made in this proposal are insulting, it wrongly assumes so called retail traders are uneducated in many of the products named in this proposal. The assumption non-professional traders lack understanding of these products is not what I see on a daily basis. I trade with hundreds of other traders in a Discord chat room and see a consistent regular progression by new traders who join. This progression generally consists of having a general understanding of stocks which then leads to naked options(calls or puts), then to multi-leg strategies followed by futures. This learning progression is made possible by the massive amount of free and informative information available on the internet whether its videos, blogs, chat rooms etc. The learning curve varies for each individual trader and depends on many factors but is ultimately up to the individual. Proposals suggesting general testing guidelines will only drive people to seek out testing strategies just to get by the test themselves, this is evident in most general testing programs similar to what is being proposed here. To be honest this entire proposal seems like busy work to show "we did something" for a problem that most likely exists at much less frequency then assumed by this organization. The one problem we see day in day out that is NOT proposed here is removing the pattern day trading requirement, which is the number 1 problem new traders encounter and makes zero sense. If this organization actually interviewed retail traders they would find the list of issues would be vastly different then what is being proposed here. There seems to be a desire to treat retail traders like children instead of focusing on real issues being discussed on a daily basis. Here's a couple: Open dark pool data up to the public, I use a service for $100 a month which provides me with the feed why isn't this data available for much much less or for free by the exchanges? Remove the pattern day trader rule, its a stupid rule and causes more problems then it solves. Provide risk management frameworks, if your really concerned about "stupid retail, then provide them with frameworks to manage risk.