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A.J Walker Comment On Regulatory Notice 22-08

A.J Walker
N/A

To the fine folks at FINRA and the SEC -

Enough is enough. Over the years your efforts to protect investors from predatory industry practices have been nothing but stellar. But at some point in the last 20 years or so, you have jumped the proverbial shark. I have watched as the requirements for disclosure, for the tiny-print that extends to infinity (and beyond), all part of a steady yet woefully misguided march towards somehow protecting investors from themselves have become ridiculously cumbersome and exceedingly ineffective.

At some point, and that point is now, you MUST recognize that you can't protect the lowest common denominator from itself and still have open and efficiently functioning markets for the rest of us. With this proposal, you are running akin to the DEA's efforts aimed at the worst of the junkies that puts the burdens on the folks who know better.

Just as the responsible user of a prescribed medication now must jump through unduly burdensome steps due to the junkies misguided behavior, now to you want to make responsible users of valuable investment tools undertake additional, and unduly burdensome efforts due to those that can't grasp the idea of "buyer beware".

If I can do my homework? If I can study? If I can grasp the true nature of these products, and use them thoughtfully and judiciously to better my long-run financial situation -- both in terms of return enhancement as well as risk management -- then have I not done enough??? Why must I do more because others won't do anything to understand markets and products?

Further, how is such a program even workable??? Is this just another dollar grab attempt by a self-governing body looking down the barrel of dwindling membership? Dwindling membership, might I add, largely due to market professionals wanting nothing to do with you because of your continued over-reach? Are you going to put in tests for every product, for every investor, and charge them a fee for the right to purchase products that you deem dumbed-down enough for them? All of this is illogical because you are attempting to do the impossible.

Not only is this entirely illogical, it is an overreach of your duty and your authority. Regulate markets all you like. But stop acting like you have a magic bullet to regulate people from doing the stupid things that stupid people do and putting the burden on all others who put in the work.

Nanny-state overreach is how you push life-long (D) voters over into voting for the hands-off approach of the (R)'s.

Enough is enough.