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Charles Layne Comment On Regulatory Notice 22-08

Charles Layne
N/A

I oppose the various impositions and restrictions on my ability to invest that are being proposed in Regulatory Notice #22-08.
(1) I am particularly concerned that the application of the term "complex" is not well-defined or specified in this notice and may grow to include anything that FINRA considers on its own volition as being too "complex" for whoever they consider incapable of understanding them.
(2) I currently use financial products in my trading and investment portfolios that I once considered "complex:" options, cryptocurrencies, short stock & options, inverse ETFs, and ETFs that use futures. Because of my willingness to learn and experience these products, they are no longer "complex." Indeed, at one time, simply buying and selling shares of common stock was "complex."
(3) I have spent nearly four decades developing my abilities as an independent, self-directed retail investor and trader. The regulations that are currently in place have served me well enough to this point, and I am certain that they will continue to serve me just fine without these additional restrictions that would negatively impact the abilities I have accumulated throughout these years.
(4) I am also concerned about proposed FINRA provisions that allow the use of certain financial products to only accounts with regulator-determined capital sizes. The brokerage firms, at least the ones I use, take care of that with their risk considerations. One of the many investment and trading mechanics I have learned over the years is that an individual, self-directed retail trader can effectively make higher probability trades using short option strategies with an account size as small as $3,000-$5,000.
(5) It stands to reason that financial regulatory bodies should enact regulations that benefit, not restrict, the abilities and capabilities of the independent, self-directed investor/trader... as well as every other type of investor/trader.

Thank you for this opportunity to comment on FINRA Regulatory Notice #22-08.