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Mark Lynch Comment On Regulatory Notice 22-08

Mark Lynch
N/A

Gentlemen, I am a fully accredited investor who selects from wide body of publicly available investments, including currencies, commodities, equities, and fixed income, both long and inverse, predominantly through ETF's. I fully understand the risks inherent in investing, especially the ramifications of investing in inverse funds, which reset daily. I use inverse ETF's to hedge and protect my investments, especially in markets that are trending lower. I am curious as to why FINRA would want to restrict these investments, leveraged or un-leveraged, as they provide an important means of investing through a full investing cycle. I do not see a need to restrict their use, nor the need for a regulator-imposed test, nor special broker permissions. I have been successful in my own self-education in these tools and deploying them when prudent. What is critically important is for individuals to learn proper portfolio sizing based on a full understanding of risk management. One cannot use these tools without appropriately sizing, visiting their portfolio daily and utilizing stops as appropriate. To not do so is tantamount to negligence. If anything, I would recommend providing on-line investment and risk management education. Such education would be hugely beneficial to novice investors. The uneducated are the issue. But is there a need for a formal gating procedure? I do not think so. Individuals should be responsible for their own actions and decisions. Promote education.