Please. I beg you. We, the public, are not your children. Please stop treating us as such.
If we have funds sufficient to invest, then we have shown that we have sufficient wherewithal to read and understand a contract. Let us.
Several years ago I was granted shares under an Employee Stock Purchase Plan, through eTrade. Upon one grant, I observed that the stock was on an upward run. I sought to capture the increase and yet, get out when the market reached a crescendo. It took but 10 minutes on the eTrade help files to determine I could make a 'Stop-Loss' order and meet my requirements.
Yet, try as I may, I could not. A call to the trading desk; and he, too, was unable to complete my order. This resulted in an escalation to 'Second Level Support'. There at last we found the issue; my employer had, when creating my account, limited my trades to simply Buy, or Sell, only to be executed immediately and at Market. This, explained this Second Level Support person, was to separate and protect the unknowledgeable from a "trained trader such as yourself".
I spent 10 minutes reading the documentation! This made me "trained"?!?
Herein lays the failure of the proposed regulation.
The transactions that are proposed to be restricted are not 'complex'. Is it wise that an investor understand the investment they intend to engage in? Certainly! Should that knowledge be imposed? Why? To bet at the recent Kentucky Derby, one did not have to show that they were knowledgeable in horsemanship or large animal veterinary. To engage in any investment with savings bonds, are we required to know the difference between CPI, LIBOR and the Federal Funds Rate? Certainly not. The federal government accepts the funds of both rich and wise & and poor and ignorant. To invest, one must pass past at least one instance of investments may both increase and lose value". Again, Of Course! That is exactly why an investor makes an investment.
Neither are these transactions "only for the rich", and that is exactly what 'net worth' requirements impose. Is it the intent to restrict profit to only those who have found 'other' sources of income? Is 'investment' and opportunity restricted to the rich? If that is so, why has the government placed incentives that we invest towards retirement, on our own? If 'investing' is only for the wealthy, should not ALL investments be restricted and Social Security be expanded to provide a full and fair 'living wage'.
The imposition of a 'cooling off' period is likewise ill begotten. If institutions are accelerating trading to the point that micro-second computer trades are required - what is the intent? To simply hobble the investor and favor the institutions? This makes no sense in achieving the stated objectives. So what are the unspoken objectives?
This regulation may have its roots in wisdom, but it Its execution is clumsy and fails to meet the reasons as extended.
J. Jakim Comment On Regulatory Notice 22-08
Please. I beg you. We, the public, are not your children. Please stop treating us as such.
If we have funds sufficient to invest, then we have shown that we have sufficient wherewithal to read and understand a contract. Let us.
Several years ago I was granted shares under an Employee Stock Purchase Plan, through eTrade. Upon one grant, I observed that the stock was on an upward run. I sought to capture the increase and yet, get out when the market reached a crescendo. It took but 10 minutes on the eTrade help files to determine I could make a 'Stop-Loss' order and meet my requirements.
Yet, try as I may, I could not. A call to the trading desk; and he, too, was unable to complete my order. This resulted in an escalation to 'Second Level Support'. There at last we found the issue; my employer had, when creating my account, limited my trades to simply Buy, or Sell, only to be executed immediately and at Market. This, explained this Second Level Support person, was to separate and protect the unknowledgeable from a "trained trader such as yourself".
I spent 10 minutes reading the documentation! This made me "trained"?!?
Herein lays the failure of the proposed regulation.
The transactions that are proposed to be restricted are not 'complex'. Is it wise that an investor understand the investment they intend to engage in? Certainly! Should that knowledge be imposed? Why? To bet at the recent Kentucky Derby, one did not have to show that they were knowledgeable in horsemanship or large animal veterinary. To engage in any investment with savings bonds, are we required to know the difference between CPI, LIBOR and the Federal Funds Rate? Certainly not. The federal government accepts the funds of both rich and wise & and poor and ignorant. To invest, one must pass past at least one instance of investments may both increase and lose value". Again, Of Course! That is exactly why an investor makes an investment.
Neither are these transactions "only for the rich", and that is exactly what 'net worth' requirements impose. Is it the intent to restrict profit to only those who have found 'other' sources of income? Is 'investment' and opportunity restricted to the rich? If that is so, why has the government placed incentives that we invest towards retirement, on our own? If 'investing' is only for the wealthy, should not ALL investments be restricted and Social Security be expanded to provide a full and fair 'living wage'.
The imposition of a 'cooling off' period is likewise ill begotten. If institutions are accelerating trading to the point that micro-second computer trades are required - what is the intent? To simply hobble the investor and favor the institutions? This makes no sense in achieving the stated objectives. So what are the unspoken objectives?
This regulation may have its roots in wisdom, but it Its execution is clumsy and fails to meet the reasons as extended.
Do not pass this regulation.