I won't speak to all "complex products" - but the vague, undefined and arbitrary definition should be more tightly drafted to not include or restrict retail customer access to investments as relatively simple as a 2x or 3x index-based fund. These types of investment can help pass along economies of scale with respect to borrowing and therefore increase access to the markets for precisely the type of investors increased regulation would hinder, with far less risk than 'simple' but highly volatile stocks or funds. The fact that in volatile markets such investments may not result long-term in an actual 2x or 3x rise or fall is well-known, and if that is your concern, then increase general education and awareness - don't restrict consumers' ability to invest. There are far more opaque or misunderstood risks in actively managed funds than the much simpler passively managed leveraged index-based fund. Investment is not for the wealthy alone, and this is not the sort of increased regulation our markets need. "Leveraged" does not equal "complex" and any definition of "complex" should not include products solely on that basis.
Anonymous Comment On Regulatory Notice 22-08
I won't speak to all "complex products" - but the vague, undefined and arbitrary definition should be more tightly drafted to not include or restrict retail customer access to investments as relatively simple as a 2x or 3x index-based fund. These types of investment can help pass along economies of scale with respect to borrowing and therefore increase access to the markets for precisely the type of investors increased regulation would hinder, with far less risk than 'simple' but highly volatile stocks or funds. The fact that in volatile markets such investments may not result long-term in an actual 2x or 3x rise or fall is well-known, and if that is your concern, then increase general education and awareness - don't restrict consumers' ability to invest. There are far more opaque or misunderstood risks in actively managed funds than the much simpler passively managed leveraged index-based fund. Investment is not for the wealthy alone, and this is not the sort of increased regulation our markets need. "Leveraged" does not equal "complex" and any definition of "complex" should not include products solely on that basis.