Here in USA we believe in freedom, and that it bears responsibility for your choices, including the potential loss of invested principal. While i'm not really concerned about a knowledge test (which i find tho useless, easy to cheat on and just another taxpayer and investor added cost), brokerage approval or certifying reading the materials, as we do believe education is important before making an investment decision, i do oppose limitations that would make these innovative alternative investments unavailable to the general public, retail investor, including me: 1. Limiting only to accredited investors: High net-worth or high income individuals already have more venues to increase their wealth, unavailable to "the little guy" like private companies, venture capital, not listed REIT, etc. So i disagree that in the name of "protecting the average little guy" from himself(!) we should make any of these investments inaccessible to the general public. I, as many others, could simply see this regulation as a rule to discourage upper mobility and protect the old-money from any new comers. Again, Public investments should be available to all of the public, not just the privileged. We need more transparency, and more accessibility for the general public to these closed markets, not less (there already are private exchanges for private companies, but you need over 100K to take part in them, like forgeglobal, angellist, startengine, equityzen). 2. "Going through cooling off periods during which you cant invest This i also oppose, despite the fact that i don't use them for long term or too often. I would not give FINRA the authority to limit my ability to make investments to inverse/short ETFs during market corrections. That would put me on the sideline when market crashes and opportunity is there still, apart from waiting... As i use them in my portfolio strategy: Leveraged, inverse, crypto, and unlisted companies funds are important to my investment strategies. They are a limited part of my overall portfolio (less than 2%, even after excluding 401k/IRA/ESA, if adding not listed REIT it is still under 5%, and adding private capital investments it is barely reaching the 5% allocation), helping me obtain both greater returns on some investments to compensate for fixed income and other lower performing safe investments, and also the inverse ones, used on a limited time frame, occasionally helping me protect against market downturns, when everything else is going down.
Paul Butuc Comment On Regulatory Notice 22-08
Here in USA we believe in freedom, and that it bears responsibility for your choices, including the potential loss of invested principal. While i'm not really concerned about a knowledge test (which i find tho useless, easy to cheat on and just another taxpayer and investor added cost), brokerage approval or certifying reading the materials, as we do believe education is important before making an investment decision, i do oppose limitations that would make these innovative alternative investments unavailable to the general public, retail investor, including me: 1. Limiting only to accredited investors: High net-worth or high income individuals already have more venues to increase their wealth, unavailable to "the little guy" like private companies, venture capital, not listed REIT, etc. So i disagree that in the name of "protecting the average little guy" from himself(!) we should make any of these investments inaccessible to the general public. I, as many others, could simply see this regulation as a rule to discourage upper mobility and protect the old-money from any new comers. Again, Public investments should be available to all of the public, not just the privileged. We need more transparency, and more accessibility for the general public to these closed markets, not less (there already are private exchanges for private companies, but you need over 100K to take part in them, like forgeglobal, angellist, startengine, equityzen). 2. "Going through cooling off periods during which you cant invest This i also oppose, despite the fact that i don't use them for long term or too often. I would not give FINRA the authority to limit my ability to make investments to inverse/short ETFs during market corrections. That would put me on the sideline when market crashes and opportunity is there still, apart from waiting... As i use them in my portfolio strategy: Leveraged, inverse, crypto, and unlisted companies funds are important to my investment strategies. They are a limited part of my overall portfolio (less than 2%, even after excluding 401k/IRA/ESA, if adding not listed REIT it is still under 5%, and adding private capital investments it is barely reaching the 5% allocation), helping me obtain both greater returns on some investments to compensate for fixed income and other lower performing safe investments, and also the inverse ones, used on a limited time frame, occasionally helping me protect against market downturns, when everything else is going down.