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Christopher Patterson Comment On Regulatory Notice 22-08

Christopher Patterson
Student

Hello,
My name is Christopher Francis Lewis Patterson. I am an non-traditional, first generation undergraduate Business Information Systems Major communicating to you in the midst of finals at CSUDH Dominguez Hills in Carson, California. There’s a lot of other details about me that you may find interesting relating to my upcoming dialogue, but that’s not what this comment is about.
I would like FINRA’s constituents and regulatory controllers that although their sincere goodwill is more than likely the motivating factor of this motion, pulling the reigns on a recently released financial product of this nature furthermore challenges the intentions of oversight as the details included in this motion have some features that I personally find to be gatekeeping oriented, and furthermore demonstrates an impasse attitude towards how negatively this product’s ability to flourish is being impacted by regulatory pressure. So you’re aware, I have no ties to government entities, and otherwise pose no immediate threat to anyone else’s financial success from the perspective of being able to access invaluable information. I am considered from your perspective a guppy in the water.
My critical perspective on how these financial products are being implemented come from a daily American misconception that mortgage products are intended for suits and ties and end up leasing property in well protected areas, while financial products that clearly negatively impact consumers are given lease space in low-income communities despite their close proximity to at risk individuals. We are aware of the dark history of our country and the existing polarization of minority populations to cities, while their buying power has been limited by means of systematic suppression and outright violent terrorism against their prosperous economic successes. This causes low-income communities within cities to become “melting pots” of our society, and although this bill demonstrates an attitude of concern; the fact remains that this move does not carefully consider the undeniable reason why many stockholders of this financial product want a safer alternative to directly purchasing something once previously dubbed: “the riskiest financial product on the market” that is currently being streamlined to low income communities without proper educational resources available.
The age of technology has since changed the access points of financial products such as brokerages, banking services, and negatively structured lending options such as a payday loan (which to this day I don’t recall ever seeing payday loan services advertised in high income communities… correct me if I’m wrong).
Many key issues I believe have not been confronted in this sector in particular, are practical steps that if good will was the orientation of this narrative/motion, should have been proactively addressed first prior to targeting a financial product of this nature that other than regulatory pressures has no other underlying reason for poor performance in the recent months. Furthermore, this demonstrates an impasse attitude and questionable motives behind an unprecedented handicap whilst repeating historic woes. One instrumental and undeniable issue would be the heavy marketing with low education base of products such as Square’s successful product CashApp, which has been a point of access for low income communities to access cryptocurrency and host a digital wallet. Now, there’s nothing wrong with giving access to digital currency in my opinion; however my argument is that there is not enough compelling information that demonstrates why a product with such fickle educational base compared to just about every other cryptocurrency exchange on the market is given so much agency in this sector to make a merge of this proportion without being ‘checked and balanced’. This has a lot to do with the fact that Square has given low income consumers the ability to bank and transfer funds easily that would have otherwise had problems hurdling access to traditional banking products of similar caliber. Yet, compounded with a superficial level of improvement to it’s educational base (which is an unregulated arena of the cryptocurrency exchange, offered educational products available have been at best a generous measure from exchanges). Due to the intersectionality of technology products like applications, a wider range of consumers are able to access these products through direct means of cryptocurrency exchanges that have dedicated access to these services. Yet, the exposure event is provided by a product like cash app that had immeasurable metamorphosis and growth since it’s dynamic to develop cryptocurrency products started. This product’s previous uses masqueraded Inyo providing direct access to bitcoin, a more unpredictable and potentially a targeted basis of concern regarding regulatory notice 12-03.
I am by no means trying to crucify cash app for lacking sufficient educational resources, and am only using this as a mere example to demonstrate my frustration at the misguided attempt to control consumer risk. I would say that BITO, BTF, and XBTF have a burden of responsibility to provide the most transparent information as well as other diversified products with incalculable risk. I would say that the year has not facilitated opportunity for that to happen organically. From where I stand, the transmission of documents I received from my brokerage firm gave me a better depiction of what the financial products intended to do than I had prior to buying in. However, I must say I bought in days after I heard about it. To say that there’s a positive compass behind the intentions of listing and cooperating with leveraged products depends heavily on the performance of their riskier counterparts. Yet, this product was given an aggressive approach compared to irresponsible contenders that FINRA has had undeniable responsibility to investigate and halt that remain on the market. One of those happens to be Citadel’s Robinhood, and I believe that there’s control based reasons why Robinhood will still remain a gatekeeper to the financial market and now the cryptocurrency market.
In my opinion, the burden of culpability rests on the shoulders of the constituents that decide to make these loop-sided decisions and increase barriers of access to low income communities. If such a calculated action is taken with so many more impacting features remain in tact, it’s reasoning needs to fit the narrative imposed. I doubt that these considerations will take place in time, and that moves to segregate access through these fine-comb tactics prove less beneficial to the consumers who inquire than not. Negotiation and improvement deserves to remain an option on the table for these products as well as other exchange traded products, as they should not be treated with impunity as they have for mobilizing cryptocurrency when systematic indifference is at play. These issues require more research as new, revolutionary products expand the educational curve behind the implied risk involved. Moreover, Regulatory Notice 12-03 seems to broadly incapacitate products with it’s language and create barriers to access without meaningful explanation on restricting the average consumer’s right to act. I would be more than happy to invest time to research these issues in a formal format if you’re open to facilitation.
Best regards,
Christopher Patterson