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Peter Franz Comment On Regulatory Notice 22-08

Peter Franz
NA retail investor

In respect to derivative based VIX ETFs and Options on those VIX ETFs, Retail Investors do not understand these complex VIX ETPs. It is not the investor "may" not understand, but "does not" understand. These complex VIX ETFs like Proshares ETF UVXY are unsuitable for investors. The sponsors need 150+ pages of expert financial wall street and securities legal verbiage to attempt to explain the VIX ETP in a prospectus. Retail investors hold investments for more than one day. Investors save for 30 years only to lose 90% of their investment and retirement accounts in months due to unsuitable products being able to be purchased in any online account as a customer of a broker dealer. I know many retail investors who lost 90% of the investments in Vix ETPs. In the past 15 years, self directed accounts have become the norm . The sponsors and broker dealers and their personnel are the experts not the investor. The investor needs more protection.