I've invested in closed-end municipal bond and infrastructure mutual funds for 30-years that use a small amount of leverage to enhance performance. They give me much better and more stable returns than any government bond without the individual stock risk of owning only a few individual stocks. Your new rule would not only potentially lock me out of investing in what I want, totally understand, and have had success with, but could greatly harm the value of my long term holdings as investors that don't want to take tests and go through bureaucratic red tape bail out of their positions. I pay my CPA about $500 extra every year to comply with FACTA draconian requirements for my single Swiss annuity for my retirement income and don't want to have to pay more to comply with this new rule. Don't implement it.
Bruce Artwick Comment On Regulatory Notice 22-08
I've invested in closed-end municipal bond and infrastructure mutual funds for 30-years that use a small amount of leverage to enhance performance. They give me much better and more stable returns than any government bond without the individual stock risk of owning only a few individual stocks. Your new rule would not only potentially lock me out of investing in what I want, totally understand, and have had success with, but could greatly harm the value of my long term holdings as investors that don't want to take tests and go through bureaucratic red tape bail out of their positions. I pay my CPA about $500 extra every year to comply with FACTA draconian requirements for my single Swiss annuity for my retirement income and don't want to have to pay more to comply with this new rule. Don't implement it.