David Brown Comment On Regulatory Notice 22-08
This so called ban will hurt me greatly in my ability to manage my portfolio in a volatile environment.
For the Public
FINRA Data provides non-commercial use of data, specifically the ability to save data views and create and manage a Bond Watchlist.
For Industry Professionals
Registered representatives can fulfill Continuing Education requirements, view their industry CRD record and perform other compliance tasks.
For Member Firms
Firm compliance professionals can access filings and requests, run reports and submit support tickets.
This so called ban will hurt me greatly in my ability to manage my portfolio in a volatile environment.
I do not want regulations to stop me from investing. I would like to be well educated, so maybe put an education process in place where we could break it down simply, by bullet points and not with the fine print.
If you are going to regulate, please focus on the documentation and education processes.
Using leveraged funds help to protect my other investments in my diversified portfolio.
I should be able to buy any stock offered publicly and not be required to take any special tests unless I decide to become a broker myself. I know the risks associated with owning any stocks and leveraged or inverse funds really don't pose anymore risk than owning any other stock. This is a free country and I want it kept that way.
Please do not put restrictions on who can and cannot purchase leveraged funds. These types of investments should be made available to the public, not just the rich.
I am a small private investor who uses inverse and leveraged funds to protect my modest portfolio from from adverse market moves. Hampering my ability to use these investment vehicles would be a travesty of freedom and unamerican. DO NOT hinder my ability to protect my family and my retirement funds from these form of protection. YES...protection! Because that is exactly how they are used by me and many investors I know.
I recognize that some investors do not fully appreciate the risks of investing in these funds. However, for investors who understand them, they represent one of the few ways non-high net worth investors can simulate the strategies of hedge funds restricted to high net worth individuals. They level the playing field especially inverse funds whose implicit interest rates are much lower than the margin rates charged by brokers to small investors.
We should have right to choose the public investments without any restrictions
Please do not over regulate my ability to invest as I see necessary.
I am a client associate at Merrill Lynch (soon to be registered client associate after passing my Series 7 and 66) and I recently passed the SIE. I fully understand the mechanisms behind leveraged/inverse products. Limiting the accessibility of these products is not in an individuals best interest because they should be allowed to make their own risk/reward judgements. 25% of my portfolio is allocated to triple leveraged funds to potentially enhance my returns without taking on an extraordinary level of risk.