To whom it may concern,
FINRA has proposed a raft of potential restrictions on so-called "complex" investment products, among them leveraged and inverse funds. Whereas some of the proposed restrictions are at least somewhat reasonable, like passing some sort of rudimentary test to ensure the investor is aware of what the product is, others are downright outrageous, such as not
Comments: I do believe having transparency is important. Regulators have done great things in the past to clarify concepts that a layman does not interact with regularly. Thanks to regulators, banks have to disclose APR's with clients, ensuring that the risks are fully understood. However, I feel that this level of scrutiny is unwarranted, biased, exclusionary, and has an unfair impact
Raising additional barriers to entry different types of investments runs a serious risk of exacerbating economic inequality. Public knowledge of investing topics has increased dramatically over the last few years as access to the market has improved for general public. There will always be those who choose riskier investments and there will always be those who choose safer investments, but it
To FINRA:
I'm a former member of FINRA, previous holder of multiple securities licenses (for over 20 years) and former registered rep and principle. I'm writing to comment and provide feedback on the proposed limitations in this regulatory notice.
I strongly oppose limitations on my (and other retail investors) ability to utilize both leveraged and inverse ETFs to achieve my
There are a number of "complex" investment instruments available to the public which enhance ones ability to manage investment risk (which has been very beneficial today with the major indexes down 15-20% for the year). These tools are advantageous and are no more difficult to understand or risky then other investment instruments (i.e. options, industry and specialized ETF's,
As an individual investor I consider
leveraged and inverse investment funds very useful to manage risk in my overall investment portfolio. They represent a minority but important percentage of my overall portfolio and are utilized to help offset and mitigate risk in my more Substantial longer term positions on a short term basis, avoiding disruptive transactions in my long term holdings.
I am
Comments: Im concerned that FINRA will attempt to strip away the ability for these products to be used effectively by active traders who use these complex products for what they were made for, short-term active trading. I understand why you would want to help those who use these for the wrong reasons, such as long-term investing, what they were not made for.
I agree that brokers could do a better
I have been investing some of my savings in the markets responsibly for almost 20 years and I respectfully oppose plans for restrictions on my right to invest in public investments that professional investors have access to. This kind of regulation would achieve the exact opposite of its intent of protecting "small investors" like myself. I should be able to educate myself, follow
Regardless of what (if any) action is taken on this notice, the decision to invest must be with the investor. Limiting retail traders' use of complex instruments represents a dangerous slippery slope. I'm all in favor of curbing advertisements for these products. Likewise, leveraged products should provide clear disclosures detailing their risk profiles and internal workings.
I would like to weigh-in on the regulations being considered by the Financial Industry Regulatory Authority (FINRA), to limit the availability of individual investors investing in leveraged and inverse funds, and other like investments without strict testing and special approvals by their broker.
Its my opinion that some brokers, who are part of FINRA are the reason that people like me seek other
