Skip to main content

Benjamin Gudlewski Comment On Regulatory Notice 22-08

Benjamin Gudlewski
N/A

I'm outraged and terrified that FINRA would consider putting restrictions on leveraged and inverse investment vehicles. These are extremely valuable tools that I use to achieve the market exposure I want to have. Without these I would need to use other methods which would incur more costs, present more risk to me, and be less tax efficient. I've worked too hard in my career to have my investment strategies upended by regulators who are going to be doing more harm than good with these proposed regulations. There is no justification for putting restrictions on these investment funds other than that you think I'm stupid and want to control my money. Butt out.

I should be able to choose the public investments that are right for me and my family. Public investments should be available to all of the public, not just the privileged.

I shouldn't have to go through any special process like passing a test before I can invest in public securities, like leveraged and inverse funds. I can read and understand a prospectus and I am capable of understanding the risks involved with leveraged and inverse investment vehicles. I don't want these measures imposed on me.

Imposing these restrictions will force me and others to use options, margin, and other strategies which have potentially higher fees and risks. These proposed regulations will benefit brokerages and hedge funds which collect on those fees and transaction costs at my expense.

Regulations are important to protect the public, but this goes too far. Put efforts to regulate scams and Ponzi schemes, or even payment-for-order-flow. But don't go after an investment vehicle because it is "too complex." Everything in the world is complex and potentially dangerous. Should I not be allowed to have electricity in my house until I demonstrate knowledge of Maxwell's equations and electromagnetism because I might electrocute myself otherwise? Your justification that there is complexity and people could get hurt might as well be used to restrict all credit cards, mortgages, bank accounts, brokerages, 401k's, etc. What you are proposing here is overly broad, arbitrarily applied, and I don't want or need these restrictions.