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Maxwell Andrews Comment On Regulatory Notice 22-08

maxwell andrews
N/A

Hello, I am a retail investor who regularly buys and sells leveraged index fund products. I trade these funds based on a strategy I have developed with great research and care, and know full well the risks involved. Leveraged index funds provide retail investors access to position-sizing and diversification strategies that would be too onerous for such investors to implement themselves. Implementing restrictions on retail investors to access these leveraged products would only harm retail investors by limiting their options and access to the best available tools, it would force them to instead pay margin interest for leveraged positions that may be many times higher than the leveraged fund fees. A test of net worth for access to products is fundamentally undemocratic - there is no correlation between net worth and investing knowledge, and this should not be a determining factor in access to advanced financial instruments. In fact, leveraged funds have made the investing environment much MORE democratic by providing access to these advanced tools for low costs without the obfuscation of brokers or wealth managers. This allows investors to succeed due to their merits rather than their predisposed financial status. The risks associated with these instruments are clearly enumerated in the prospectus according to current regulatory requirements. I see no need for additional restrictions or regulations, and any such restrictions would personally harm my current positions established in such products, as well as my ability to implement my long-developed investing strategy, which is contingent on the availability of such products. If FINRA were to restrict my retail access to such products, I would be personally harmed greatly and my strategies in progress would be interrupted, resulting in acute financial losses with no ability to recover them. I suggest that if FINRA wants to make sure retail investors understand the risks of investing in such leveraged instruments, that they should apply their resources toward education rather than regulatory overreach and punishment of retail investors. I implore FINRA to abandon any restrictions under consideration and leave retail investors unmolested - leveraged funds are one of the best tools we have to level the playing field with wall street insiders. Taking these tools away would only serve to deepen retail investing inequality and distort the smooth and natural function of markets.