REQUEST FOR COMMENTSubordination AgreementsComment Period Expires November 26, 2004SUGGESTED ROUTINGKEY TOPICSLegal & ComplianceOperationsSenior ManagementAppendix D to the Net Capital RuleNet CapitalSEC Rule 15c3-1Subordination AgreementsSubordinated LoansExecutive SummaryIn 2002, NASD adopted a requirement that firms submitting subordination agreements to NASD staff for approval provide
I oppose restrictions being placed on my right to choose and invest in stocks/bonds/annuities/funds/ETFs/crypto with my own resources as I see fit.
I have been investing for nearly 30 years, carefully researching the products I trade without relying on any particular broker nor adviser. I have recently added cryptocurrency assets, including BITO Proshares. I view this as an additional branch to
To whom it concerns at the FINRA. I have heard that y'all are considering adding regulations to leverage and inverse funds. I strongly oppose additional regulations as I believe such regulations will burden investors and our saving goals. Regulators should not be in charge which public investments I would like to choose, they already regulate 14% of our salaries for social security.
I strongly disagree with the addition of any new oversight related to leveraged and particularly inverse etf's. I use them to hedge/protect my family's assets particularly in periods of heightened volatility, which is becoming increasingly frequent as the machines/algorithms have taken over trading (an area that regulators don't appear to be overly concerned with).
Please see comments.
Pass a regulator-imposed test of your specialized investment knowledge
-- This should be a few questions, not complex, just a couple basics.
Demonstrate a high net worth
-- Not high. $2,000 or something like that.
Get special approval from your broker
-- Not special approval, just the broker sees the $value, asks the questions, and then approves.
Attest to reading
I understand the complex nature of these investment products. I like how the lower market price of these index price values compared to the S&P market value prices allow for smaller investors to capitalize on S&P 500 market value fluctuation values. We as smaller value investors need the ability to invest in larger markets without restriction.
If is extremely important for investors to decide what is safe and what is risky. You, the regulator, must ensure proper documentation is disclosed on the nature of investment indfrurmenf and no fraud is occurring.
Otherwise let capital markets operate freely for the "little" guys who aren't multi millionaires.
Leveraged and inverse funds areimportantto my investment
I understand that regulations being considered by FINRA might impact my ability to invest in leveraged funds or place an unnecessary burden on being able to do so. I have been managing my portfolio for only a few years now and am on a fast learning curve. Investing in a triple leveraged index fund was not such a hard decision and I put less than 5% of my total wealth in it. I've made
I believe that leveraged ETFs have their place. They allow a smaller dollar amount of capital to be at risk for roughly the same potential returns. They certainly are not for everybody and one should be made very aware of the risks, tracking errors, and internal costs. It should be stressed to the public about the pros and the cons of their usage and the importance of position sizing if
(a) ApplicationThis Rule shall apply exclusively to the activities of members in connection with the securities of companies registered under the Investment Company Act; provided however, that Rule 2320 shall apply, in lieu of this Rule, to members' activities in connection with "variable contracts" as defined therein.(b) Definitions(1) The terms "affiliated member,"
