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Gary Lee Comment On Regulatory Notice 22-08

Gary Lee
N/A

INANE!!!

If enacted the proposed restrictions of FINRA Regulatory Notice #22-08 would reduce my ability to hedge and thereby would INCREASE the risk in my portfolio. The proposed regulation is another example of cognitive biases in the actions of regulatory agencies. In this case the main ones, among others, being the Illusion of Explanatory Depth, or IOED, and Regulatory bias.

I am certainly able to comprehend the risk associated with my use of leveraged and inverse funds:

I passed the Series 7 exam at the top of my class when I became a stock broker.

When employed as a manager in a Junk Bond investment group I anticipated the coming collapse of the junk bond market and resigned my position well before the crash.

Subsequently, I was V.P./ Portfolio Manager for an institutional money management firm with the sole responsibility for a $1.6 billion investment grade fixed income portfolio.

I earned a M.A. and completed the course work, but not the dissertation, required for a PhD. in Economics at the #1 public university in the U.S. One of my fields dealt with antitrust and regulation. I also have a degree in Political Science and probably have read enough Philosophy to have earned a degree in that field as well.

In October of '87 I predicted the debacle in the market two weeks before it occurred.

At the top of the dot com bubble I predicted the Nasdaq market would collapse from 4,600 to 1,500. I was wrong, it fell to 1,200.

I am opposed to the proposed regulation, but if it is enacted, it should be obvious from my background that "one size does not fit all".
Regards,

Gary Lee