Supplemental FOCUS Filing Requirement Applicable to Certain Joint Broker-Dealers/Futures Commission Merchants
I understand the financial risk that I am taking when I purchase leveraged and inverse funds. They are important aspects of my investing strategy. Please do not restrict these assets from the marketplace. Every ETF has a place in the market. Thank you.
Please do not restrict access to geared financial products. They are a beneficial part of an overall portfolio strategy. When accounting for time horizon, percentage of portfolio, hedging, and proper asset allocation geared products fit an important need of investors.
Losing the ability to invest in leveraged funds would put me at a financial disadvantage. It would disrupt long-term investment strategies I've already undertaken. I understand the risks and only use them as a limited part of my overall assets.
Individual investors should have the right to invest in a variety of asset classes and financial securities with varying amounts of risk rather than restrict them to a privileged few (trusts, hedge funds, high net worth individuals, etc.).
SEC Approval and Effective Date for New Consolidated FINRA Rules and the Repeal of Certain NASD and Incorporated NYSE Rules
N.A. INVESTCORP LLC280 PARK AVENUE, 39TH FLOOR, NEW YORK, NY 10017N.B. ZOULLAS SECURITIES, INC.ONE PENN PLAZA, SUITE 2005, 20TH FLOOR, NEW YORK, NY 10119N.E. PRIVATE CLIENT, LTD790 NORTH MAIN STREET, PROVIDENCE, RI 02904N.I.S. FINANCIAL SERVICES, INC.500 EAST 9TH ST., KANSAS CITY, MO 64106Mailing Address: P. O. BOX 219103, KANSAS CITY, MO 64121-9103NABSECURITIES, LLC277 PARK AVENUE, 19TH FLOOR,
SUGGESTED ROUTING:*
Senior ManagementCorporate FinanceLegal & Compliance*These are suggested departments only. Others may be appropriate for your firm.
EXECUTIVE SUMMARY
The NASD requests comments on proposed amendments to Appendix F under Article III, Section 34 of the Rules of Fair Practice and Schedule D to the NASD By-Laws. The amendments would restrict member participation
R. F. LAFFERTY & CO., INC.40 WALL STREET, 29TH FLOOR, NEW YORK, NY 10005R. SEELAUS & CO., LLC26 MAIN STREET, SUITE 300, CHATHAM, NJ 07928R.J. O'BRIEN SECURITIES, LLC222 SOUTH RIVERSIDE PLAZA, SUITE 1200, CHICAGO, IL 60606Mailing Address: 222 SOUTH RIVERSIDE PLAZA, SUITE 1200, CHICAGO, IL 60606R.M. DUNCAN SECURITIES, INC.10201 W MARKHAM ST, SUITE 219, LITTLE ROCK, AR 72205R.M
FINRA Regulators:
While I understand the concern of heightened risk posed by leveraged securities, I am alarmed at the proposed measures restricting investment into these publicly traded leveraged securities, especially requirements related to net worth, because these types of investments allow the type of returns necessary for lower net worth individuals to attain financial success, and
