I am writing to express my shock and concern over the direction FIRNA believes it is necessary to move in as outline by Regulatory Notice 22-08. The entire notice is written with a thinly veiled tone of condescension towards retail investors and how they cannot possibly have the knowledge or sophistication to understand what they are investing in; a common refrain from those who clutch at their pearls when they hear of the average investor making a double digit percentage return on an option trade while paying no mind to the 5th "sophisticated" hedge fund of the year blowing itself up over a 'safe' trading strategy.
FINRA does not have the ability to determine or even test the sophistication of the average investor and simply makes the bold assumption that they are too simple-minded to understand risk properly. I can only imagine this is based off of observers within FINRA disagreeing with the investment choices retail investors make; after all FINRA knows the optimal strategy for every individual investor to invest by. This proposal goes well beyond the scope of FINRA's purpose as listed on its website:
-every investor receives the basic protections they deserve;
-anyone who sells a securities product has been tested, qualified and licensed;
-every securities product advertisement used is truthful, and not misleading;
-any securities product sold to an investor is suitable for that investor's needs; and
-investors receive complete disclosure about the investment product before purchase.
There is no outside threat to investor's here. There is no dishonesty or non-disclosure of risks involved. There is simply retail investor's investing in a way FINRA deems rudimentary and therefore wrong. Now we find it on its new, worrisome path, towards adding "ensuring no heterodox investment strategies can occur" to its list of reasons for existing as it impedes any investment strategies but the most basic (for it is the complex here you wish to eliminate) from being undertaken.
Treat investors like the adults they are and focus your resources and protecting them from malicious actors in the system instead of the decisions they make that you disagree with.
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Jacob Dee Comment On Regulatory Notice 22-08
To whom it may concern.
I am writing to express my shock and concern over the direction FIRNA believes it is necessary to move in as outline by Regulatory Notice 22-08. The entire notice is written with a thinly veiled tone of condescension towards retail investors and how they cannot possibly have the knowledge or sophistication to understand what they are investing in; a common refrain from those who clutch at their pearls when they hear of the average investor making a double digit percentage return on an option trade while paying no mind to the 5th "sophisticated" hedge fund of the year blowing itself up over a 'safe' trading strategy.
FINRA does not have the ability to determine or even test the sophistication of the average investor and simply makes the bold assumption that they are too simple-minded to understand risk properly. I can only imagine this is based off of observers within FINRA disagreeing with the investment choices retail investors make; after all FINRA knows the optimal strategy for every individual investor to invest by. This proposal goes well beyond the scope of FINRA's purpose as listed on its website:
-every investor receives the basic protections they deserve;
-anyone who sells a securities product has been tested, qualified and licensed;
-every securities product advertisement used is truthful, and not misleading;
-any securities product sold to an investor is suitable for that investor's needs; and
-investors receive complete disclosure about the investment product before purchase.
There is no outside threat to investor's here. There is no dishonesty or non-disclosure of risks involved. There is simply retail investor's investing in a way FINRA deems rudimentary and therefore wrong. Now we find it on its new, worrisome path, towards adding "ensuring no heterodox investment strategies can occur" to its list of reasons for existing as it impedes any investment strategies but the most basic (for it is the complex here you wish to eliminate) from being undertaken.
Treat investors like the adults they are and focus your resources and protecting them from malicious actors in the system instead of the decisions they make that you disagree with.
Thank you for your time.