Dear FINRA, I come from the industry, although now retired, and am an active trader using leveraged products. I agree with you that anyone using these products should be able to demonstrate sophistication and an understanding of the underlying optionality and risks. (In cases of trading discretion, the person with trading discretion over the client's, or family member's, assets should be the one attesting, with the ultimate asset owner's assent to the product's use.)
However, I disagree on a "cooling-off" period, as that likely causes the opportunity to be missed. It is important that those capable of using these products have unfettered access, once attesting to their understanding and suitability.
Eric Osserman Comment On Regulatory Notice 22-08
Dear FINRA, I come from the industry, although now retired, and am an active trader using leveraged products. I agree with you that anyone using these products should be able to demonstrate sophistication and an understanding of the underlying optionality and risks. (In cases of trading discretion, the person with trading discretion over the client's, or family member's, assets should be the one attesting, with the ultimate asset owner's assent to the product's use.)
However, I disagree on a "cooling-off" period, as that likely causes the opportunity to be missed. It is important that those capable of using these products have unfettered access, once attesting to their understanding and suitability.