Ladies and Gentlemen,
As a retired RIA and portfolio manager who spent more than 25 years managing assets and advising private clients, I object to FINRA's Notice #22-08 proposing to limit access to leveraged and inverse ETFs. While there will always be a handful of novice and unsophisticated clients who may harm themselves by trading financial instruments they don't fully
During the 2007-2009 Financial Crisis, inverse funds saved my retirement. I also have occasionally used leveraged funds because of a 24-hr shortage of "settled" funds. I do not want or need the protection afforded by the proposed measures. The Fed has routinely created bubbles in various asset classes, incentivizing investors to use leveraged long funds as the bubble expands.
Im 58 years old. I have more than ten years of investing experience and have amassed more than three millions in stock assets, mainly by using leveraged ETFs to take advantage of severe market sell offs such as 2008 financial crisis and Covid-19 pandemic. I have found that the leveraged ETFs are extremely powerful investing tools for experienced and responsible long-term investors like myself who
Dear Sir or Madame, I appreciate you hearing my comments regarding your desire to limit inverse and leveraged funds. First of all, we have a right to participate in the market in this area, since I'm aware that every large brokerage institution (bank) has the ability to short or go long the market. Why would you restrict the ability of the average investor to accomplish the same goals, and
Suitability obligations are critical to ensuring investor protection and promoting fair dealings with customers and ethical sales practices. FINRA Rule 2111 governs general suitability obligations, while certain securities are covered under other rules that may contain additional requirements.
FINRA Rule 2111 requires that a firm or associated person have a reasonable basis to believe a recommended transaction or investment strategy involving a security or securities is suitable for the customer. This is based on the information obtained through reasonable diligence of the firm or associated person to ascertain the customer’s investment profile.
The rule states that the customer’s investment profile “includes, but is not limited to, the customer’s age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs [and] risk tolerance,” among other information. A broker’s “recommendation,” which is based on the facts and circumstances of a particular case, is the triggering event for application of the rule.
Brokers must have a firm understanding of both the product and the customer, according to Rule 2111. The lack of such an understanding itself violates the suitability rule.
FINRA Reminds Firms of Their Sales Practice Obligations Relating to Principal-Protected Notes
FINRA has created this page to educate member firms on “Firm Identity Theft”.
Firms must comply with the Bank Secrecy Act and its implementing regulations ("AML rules"). The purpose of the Anti-Money Laundering (AML) rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation. FINRA reviews a firm’s compliance with AML rules under FINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program.
SUGGESTED ROUTING:*
Internal AuditOperationsSystemsTrading*These are suggested departments only. Others may be appropriate for your firm.
As of August 23, 1991, the following 53 issues joined Nasdaq/NMS, bringing the total number of issues to 2,605:
Symbol
Company
Entry Date
SOES Execution Level
VRTX
Vertex Pharmaceuticals Incorporated
7/24/91
1000
CATH
Catherines Stores
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