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Robert Boseant Comment On Regulatory Notice 22-08

Robert Boseant
N/A

As a CPA and investor for over 40 years, Im writing to express my deep concern that proposed rules being considered by FINRA will limit my access to leveraged and inverse funds. These products are an important part of my investment strategy that help me mitigate risk and protect my long-term investments during market downturns.

Balancing my long-term holdings with inverse funds allow me to hold investments during downturns and limit my potential losses. This gives me flexibility in an uncertain market and the security to stay the path with my long-term investments.

As long as investors understand these products, I do not think they are inherently risky. My brokerage includes disclosure forms when I purchase these products, which I dont mind and think creates sufficient understanding of the product up front. I understand the products and think there is less risk compared to other investment options. These leveraged funds have a manager who works to mitigate risk.

Through my brokerage account, I can keep track of my investments in these funds daily, observe their performance
over time, and make independent decisions on how to manage my funds.

I hope FINRA takes into consideration my firm belief that ordinary investors can manage our own financial decisions. These funds help me and many other investors achieve important financial goals. I do not believe FINRA should be imposing rules that restrict my access to them.