I submit that the current controls of the brokerage company when any investor invests in any leveraged ETFs / ETNs are adequate.
1. Every investor when trades in Leveraged ETFs / ETNs mandatorily signs the Designated Investments Agreement that clearly states the risk & the qualification
requirements.
2. Every time the investor places order of any Leverages ETFs / ETNs, the system displays a warning about these products.
The above measures are adequate to educate / safeguard the investors.
And so, I strongly oppose any FINRAs action to implement any additional restriction or stop investors from trading in the valuable leveraged products.
I would like to present the contents of the Designated Investments Agreement that is self-explanatory:
Designated Investments Agreement
I understand that from time to time Fidelity may determine to accept orders for certain investments (Designated Investments) only from self-directed, sophisticated, experienced, investors who have represented to Fidelity that they do their own investment research and analysis, and who do not rely to any extent upon Fidelity for advice, information or direction relating to these investments. I understand I must agree to this Designated Investments Agreement in order to purchase such investments through Fidelity. I understand that this Designated Investments Agreement applies to any and all investments that Fidelity has identified or may in the future identify as a Designated Investment. I understand that the Designated Investments list may be updated from time to time, without notice to me. I acknowledge that many complex or highly risky products are not on the Designated Investments list and that even though one or more products are not on the Designated Investments list does not mean that they are not complex or highly risky. I am not relying on Fidelity to identify all such complex or risky investments. Before making any investment, I understand I should review and understand each investment and its benefits and risks. By clicking "I Agree" below, I represent and agree:
1. I am a sophisticated, experienced investor;
2. My risk tolerance is high, and I can afford to lose some or all of any investment I make in a Designated Investment, and I have sufficient resources at Fidelity or elsewhere to sustain such losses;
3. I am responsible for educating myself regarding the investments I make including reading the applicable offering documents (including, where applicable, the prospectus and Statement of Additional Information) and any disclosures provided by Fidelity, if any, before I invest so I am aware of the investment objectives, unique features and risks of the investments as well as the fees and expenses associated with them and I have done so;
4. I independently analyze the risks of investing in Designated Investments and am capable of doing so. I make my own investment decisions and will do so as to all Designated Investments I may purchase through Fidelity;
5. Fidelity does not, and I understand will not, recommend or solicit the purchase of Designated Investments. To the extent I will have or have had communications with any Fidelity representatives about a Designated Investment, I agree I am not relying on those communications as recommendations or solicitations;
6. I have not and will not rely on Fidelity or any Fidelity representative for advice, information or recommendations regarding Designated Investments, their nature or features, their risk profiles, or their suitability for me;
7. I am not relying today and will not rely in the future on Fidelity to monitor my investments in Designated Investments nor advise me concerning them; and
8. I will promptly advise Fidelity if any of these representations are no longer true.
I understand and agree that Fidelity will rely on my representations above, and that I am bound by them as to all my accounts at Fidelity.
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Aim Hi Comment On Regulatory Notice 22-08
I submit that the current controls of the brokerage company when any investor invests in any leveraged ETFs / ETNs are adequate.
1. Every investor when trades in Leveraged ETFs / ETNs mandatorily signs the Designated Investments Agreement that clearly states the risk & the qualification
requirements.
2. Every time the investor places order of any Leverages ETFs / ETNs, the system displays a warning about these products.
The above measures are adequate to educate / safeguard the investors.
And so, I strongly oppose any FINRAs action to implement any additional restriction or stop investors from trading in the valuable leveraged products.
I would like to present the contents of the Designated Investments Agreement that is self-explanatory:
Designated Investments Agreement
I understand that from time to time Fidelity may determine to accept orders for certain investments (Designated Investments) only from self-directed, sophisticated, experienced, investors who have represented to Fidelity that they do their own investment research and analysis, and who do not rely to any extent upon Fidelity for advice, information or direction relating to these investments. I understand I must agree to this Designated Investments Agreement in order to purchase such investments through Fidelity. I understand that this Designated Investments Agreement applies to any and all investments that Fidelity has identified or may in the future identify as a Designated Investment. I understand that the Designated Investments list may be updated from time to time, without notice to me. I acknowledge that many complex or highly risky products are not on the Designated Investments list and that even though one or more products are not on the Designated Investments list does not mean that they are not complex or highly risky. I am not relying on Fidelity to identify all such complex or risky investments. Before making any investment, I understand I should review and understand each investment and its benefits and risks. By clicking "I Agree" below, I represent and agree:
1. I am a sophisticated, experienced investor;
2. My risk tolerance is high, and I can afford to lose some or all of any investment I make in a Designated Investment, and I have sufficient resources at Fidelity or elsewhere to sustain such losses;
3. I am responsible for educating myself regarding the investments I make including reading the applicable offering documents (including, where applicable, the prospectus and Statement of Additional Information) and any disclosures provided by Fidelity, if any, before I invest so I am aware of the investment objectives, unique features and risks of the investments as well as the fees and expenses associated with them and I have done so;
4. I independently analyze the risks of investing in Designated Investments and am capable of doing so. I make my own investment decisions and will do so as to all Designated Investments I may purchase through Fidelity;
5. Fidelity does not, and I understand will not, recommend or solicit the purchase of Designated Investments. To the extent I will have or have had communications with any Fidelity representatives about a Designated Investment, I agree I am not relying on those communications as recommendations or solicitations;
6. I have not and will not rely on Fidelity or any Fidelity representative for advice, information or recommendations regarding Designated Investments, their nature or features, their risk profiles, or their suitability for me;
7. I am not relying today and will not rely in the future on Fidelity to monitor my investments in Designated Investments nor advise me concerning them; and
8. I will promptly advise Fidelity if any of these representations are no longer true.
I understand and agree that Fidelity will rely on my representations above, and that I am bound by them as to all my accounts at Fidelity.