My name is Brian and I am a retail investor. I do not have a background in finance or economics and I do not have any SEC certifications. I have 3 trading accounts; a joint brokerage, an individual brokerage and an IRA. The combined balance of these accounts is about $300K. I am in my 40s and no longer hold my corporate job. I am self-employed and chose to invest my own retirement and cash/margin funds. I exclusively trade in Leveraged & Inversed ETFs/ETNs and have been doing so for several years. I UNDERSTAND THE RISKS. Fortunately with risks can come rewards so I choose to accept these risks and work to reduce them each and every trading day. The risks of these products is hyper-evident in ALL trading platforms I have ever used including TD Ameritrade, Schwab and Alight. Every time I click on a holding or intended trade with these products there are obvious warnings and disclaimers about the technical savvy I should have and the complexity of these instruments. There is plenty of legal disclaimers right now intended to send the uninformed running the other way thanks to the existing regs. The reality is that these instruments are not nearly as complex as options chains, forex, futures, crypto or pulling gains on the latest meme stocks. They are a simplified version of exactly what I seek in the market, a get in-get out trading tool (not an investment tool). These products allow me to efficiently enter and exit the market at the prices I choose whether I gain or lose when the closing bell rings. They are efficient because I can reach my goals far more quickly than I could with standard 1X stocks or ETFs, I get increased exposure to the indexes of my choice and I can earn when markets decline by easily buying the inversed product. Profiting from bearish conditions without having to execute shorts or options is just plain smart securities design. FINRA should understand in the wake of the Gamestop fiasco that retail investors are not unintelligent by any means. Although most retail traders historically do lose money in the market, this does not mean that regulators should restrict our exposure to risk. All investment carries risk; everyone knows this. If anything, crypto and options trading should be clamped down on because they are very hard to understand, trade, and profit from. Sometimes I make a 1% or so in a short period of time and sometimes I lose 1% in a short period of time. I am very comfortable with these risk and I understand exactly what I am putting on the line. Any attempt to restrict access to these products would not be motivated by anything altruistic. Please do not attempt to save us from ourselves; we don't need that. Ultimately, any restrictions would put more power in the hands of the most sophisticated institutional investors since 2X and 3X leverage would be more difficult for the rest of us to access. I welcome any follow up regarding my comments and you can reach me on this email anytime. Please do NOT restrict or change any policy associated with L&I ETFs this pinnacle of most elegant securities; securities that have been engineered to predictable perfection. There is no good alternative to the trader who choses leverage and inverse to accomplish their individual trading goals, Best Regards, -bf
Brian Foley Comment On Regulatory Notice 22-08
My name is Brian and I am a retail investor. I do not have a background in finance or economics and I do not have any SEC certifications. I have 3 trading accounts; a joint brokerage, an individual brokerage and an IRA. The combined balance of these accounts is about $300K. I am in my 40s and no longer hold my corporate job. I am self-employed and chose to invest my own retirement and cash/margin funds. I exclusively trade in Leveraged & Inversed ETFs/ETNs and have been doing so for several years. I UNDERSTAND THE RISKS. Fortunately with risks can come rewards so I choose to accept these risks and work to reduce them each and every trading day. The risks of these products is hyper-evident in ALL trading platforms I have ever used including TD Ameritrade, Schwab and Alight. Every time I click on a holding or intended trade with these products there are obvious warnings and disclaimers about the technical savvy I should have and the complexity of these instruments. There is plenty of legal disclaimers right now intended to send the uninformed running the other way thanks to the existing regs. The reality is that these instruments are not nearly as complex as options chains, forex, futures, crypto or pulling gains on the latest meme stocks. They are a simplified version of exactly what I seek in the market, a get in-get out trading tool (not an investment tool). These products allow me to efficiently enter and exit the market at the prices I choose whether I gain or lose when the closing bell rings. They are efficient because I can reach my goals far more quickly than I could with standard 1X stocks or ETFs, I get increased exposure to the indexes of my choice and I can earn when markets decline by easily buying the inversed product. Profiting from bearish conditions without having to execute shorts or options is just plain smart securities design. FINRA should understand in the wake of the Gamestop fiasco that retail investors are not unintelligent by any means. Although most retail traders historically do lose money in the market, this does not mean that regulators should restrict our exposure to risk. All investment carries risk; everyone knows this. If anything, crypto and options trading should be clamped down on because they are very hard to understand, trade, and profit from. Sometimes I make a 1% or so in a short period of time and sometimes I lose 1% in a short period of time. I am very comfortable with these risk and I understand exactly what I am putting on the line. Any attempt to restrict access to these products would not be motivated by anything altruistic. Please do not attempt to save us from ourselves; we don't need that. Ultimately, any restrictions would put more power in the hands of the most sophisticated institutional investors since 2X and 3X leverage would be more difficult for the rest of us to access. I welcome any follow up regarding my comments and you can reach me on this email anytime. Please do NOT restrict or change any policy associated with L&I ETFs this pinnacle of most elegant securities; securities that have been engineered to predictable perfection. There is no good alternative to the trader who choses leverage and inverse to accomplish their individual trading goals, Best Regards, -bf