Charles Ajamian Comment On Regulatory Notice 22-08
Charles Ajamian
N/A
I've invested for my own account over 50 years, and served as a NASD/FINRA arbitrator over 20 years. I dealt with options, high-yield funds, leveraged ETFs, and many other products. My concerns are disclosures and suitability.
Complex products require complex rules and complex disclosures. Disclosures must have a separate summary of risks in plain language, in addition to the legal language required. Additional rules and policies a member/seller may have (beyond those of FINRA or the SEC) need to be spelled out clearly, again in a separate section.
Avoid lumping people into classes (high net worth, seniors, etc.) as a condition for suitability. It risks unintended consequences. Sellers must decide each case on its own merits.
Charles Ajamian Comment On Regulatory Notice 22-08
I've invested for my own account over 50 years, and served as a NASD/FINRA arbitrator over 20 years. I dealt with options, high-yield funds, leveraged ETFs, and many other products. My concerns are disclosures and suitability.
Complex products require complex rules and complex disclosures. Disclosures must have a separate summary of risks in plain language, in addition to the legal language required. Additional rules and policies a member/seller may have (beyond those of FINRA or the SEC) need to be spelled out clearly, again in a separate section.
Avoid lumping people into classes (high net worth, seniors, etc.) as a condition for suitability. It risks unintended consequences. Sellers must decide each case on its own merits.