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Frank Commons Comment On Regulatory Notice 22-08

Frank Commons
Retired CPA and Certified Financial Planner

I am contacting you to express my opposition to the proposals in Regulatory Notice 22-08. I see no justification for FINRA to restrict public access to any publicly traded financial products, including leveraged EFTs. These securities provide an efficient and economic vehicle for small investors to hedge portfolio risk, a strategy that has now become critical in the aftermath of more than a decade of reckless policies by our Federal Reserve Governors. The current wealth gap in the United States is already at obscene levels. Making it more difficult for individuals to attempt to bridge this gap by imposing trading restrictions and/or requiring passing a government-administered test can only compound the inequities public investors face in relation to their institutional counterparts. An additional diseconomy produced by FINRA's proposed regulations, if enacted, will be to decrease liquidity in the leveraged EFT markets, producing further obstacles to the private investor in achieving his or her goals. There already are an overabundance of FINRA regulations with dubious effectiveness or practical use. The 92-page (excluding supplements) pamphlet 'Characteristics and Risks of Standardized Options' is a case in point. While required to be distributed to investors in order to purchase options, neither I nor any former clients I can recall were able to find the slightest degree of usefulness in its contents. Please do not waste time and taxpayer money creating another ineffective set of regulations with which to burden and restrict the already disadvantaged private investor.