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Craig Fisch Comment On Regulatory Notice 22-08

Craig Fisch
N/A

As a Financial Advisor, we have a small portion of our practice that uses leveraged and inverse ETFs in our clients accounts. We fully understand the risks involved. We employ multiple analytics in our decision making process, and use an active trading system in an attempt to mitigate the risks. The long-term results can be quite substantial for our clients. We feel it would not be in our clients' best interest if these products became restricted or prohibited. The proposed regulations appear to be overreach and would limit our ability to work in our clients' best interest.